Guilty Plea Does Not Bar A Constitutional Challenge To Conviction

Class v. United States

When Rodney Class was indicted for possessing firearms in his locked vehicle parked at the U.S. Capitol, he moved to dismiss on the basis that the law violated his Second Amendment and Due Process rights under the Constitution. The district court declined Class’ motion, and he entered into a written plea agreement, which did not expressly waive his right to challenge the constitutionality of the statute he was pleading guilty to violating. When he later sought to raise his constitutional argument on direct appeal, the D.C. Circuit held he had waived that argument. The Court, in a 6-3 opinion by Justice Breyer, reversed, holding that a guilty plea does not, by itself, constitute a waiver of constitutional arguments. Relying on cases up to 150 years old, the majority held that a guilty plea admits to the actions taken in violation of the law, but does not admit to the court’s authority to convict under that law. Justice Alito, joined by Justices Kennedy and Thomas, dissented, arguing that the majority’s opinion leaves a “muddle” that threatens to undermine the finality of a guilty plea.