Class v. United States
Summary
Defendant was charged with carrying a firearm on the Grounds or in any Capital Building. After indictment, Class waived his right to counsel and represented himself. Class then failed to appear at his trial and was arrested. Facing additional charges for failing to appear that carried up to 5 years in prison, Class plead guilty in return for a recommended sentence on the original charges of 0-6 months. The plea agreement did not explicitly waive Class’s right to appeal based on the constitutionality of the statute of conviction. When Class lodged such an appeal, however, the government argued it had been waived.
The D.C. Circuit agreed, finding that “unconditional guilty pleas that are knowing and intelligent… waive the pleading defendant[‘s] claims of error on appeal, even constitutional claims.” The Supreme Court, however, concluded that a guilty plea by itself does not bar a federal criminal defendant from challenging the constitutionality of the statute of conviction on direct appeal, and therefore “Class did not relinquish his right to appeal the District Court’s constitutional determinations simply by pleading guilty.”
Key Quote
“In sum, the claims at issue here do not fall within any of the categories of claims that Class’ plea agreement forbids him to raise on direct appeal. They challenge the Government’s power to criminalize Class’ (admitted) conduct. They thereby call into question the Government’s power to ‘constitutionally prosecute’ him. A guilty plea does not bar a direct appeal in these circumstances.”