Case No. 16-424 | D.C. Cir. Decision
Class v. United States may have some bearing on future defendants who choose to plead guilty. Perhaps due to misfortune, the petitioner in this case was criminally charged with possessing a weapon on Capitol grounds. Mr. Class had a concealed-carry firearm permit and unknowingly parked his car in a parking lot on the Capitol grounds during a trip to Washington, D.C. The Capitol Police noticed his car lacked the proper parking permit and executed a legal search of the car. During the search, they found several guns. A statute completely prohibits all weapons on Capitol grounds. Petitioner was arrested, charged, and eventually pled guilty as a result.
Mr. Class argued in the lower courts that the statute at issue was unconstitutional, both because it violated his Second Amendment rights and because it was unconstitutionally vague. The circuits are split on the question of whether a guilty plea waives a defendant’s right to challenge the constitutionality of his statute of conviction. The Court’s decision will likely look toward its interpretation of two previous Supreme Court decisions from the 1970s: Blackledge v. Perry, 417 U.S. 21 (1974), and Menna v. New York, 423 U.S. 61 (1975). Collectively, the Court held that a defendant who pleads guilty can still raise a constitutional claim on appeal so long as the claim is not challenging his “factual guilt.” The circuit split frames the issue in three ways: whether a guilty plea waives as-applied, but not facial, challenges to the statute of conviction; whether a guilty plea does not waive either facial or as-applied challenges; or whether a guilty plea waives both facial and as-applied challenges.
If the Court holds that a defendant’s guilty plea does not waive the defendant’s right to challenge, this case could have a large impact on future defendants challenging their statute of conviction on constitutional grounds. Considering the large number of criminal cases ending in a guilty plea, the number of appeals could certainly increase. As the government notes in its brief, however, the likelihood of success for these appeals would be slim. In only one case has an appellate court reversed a defendant’s conviction on the basis of an unconstitutional statute of conviction argument.