Class v. United States
Issues
Does a guilty plea inherently waive a defendant’s right to challenge the constitutionality of the statute underlying his conviction unless that right is explicitly preserved in the plea agreement?
This case will allow the Supreme Court to clarify the appellate rights of criminal defendants who have pled guilty and subsequently want to challenge the constitutionality of their statute of conviction. Circuit courts have been divided on the subject. Petitioner, Class, argues that the Court should apply the precedent set in Blackledge v. Perry and Menna v. New York to his case by holding that constitutional challenge claims do not challenge a defendant’s factual guilt or dispute whether the government met every burden of proving each element of the crime, and therefore are not precluded by pleading guilty. Respondent, the United States, argues that a constitutional challenge to a defendant’s statute of conviction is inherently waived in a guilty plea as an aspect of his factual guilt unless it is expressly preserved in his plea agreement. With this decision, the Supreme Court will determine the constitutional rights of all criminal defendants who plead guilty and likely impact the role guilty pleas play in United States jurisprudence.
Questions as Framed for the Court by the Parties
Whether a guilty plea inherently waives defendant’s right to challenge the constitutionality of his statute of conviction.
On May 30, 2013, Petitioner Rodney Class (“Class”) parked his Jeep, which contained guns and ammunition, in a parking lot located on the Capitol grounds on the 200 block of Maryland Avenue, SW in Washington D.C. See Brief for Petitioner, Rodney Class at 4–5. While Class visited the Capitol buildings, a police officer noticed a Jeep without the permit required to park in the lot and saw a blade and gun holster inside.
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Additional Resources
- Daniel P. Blank, Plea Bargain Waivers Reconsidered: A Legal Pragmatist's Guide to Loss, Abandonment and Alienation, 68 Fordham L. Rev. 2011 (2000).
- Jody Godoy, Justices To Decide If Guilty Plea Ends Constitutional Claims, Law360 (Feb. 21, 2017).