Class v. United States, 138 S. Ct. 798

Background

Rodney Class was indicted under 40 U.S.C. §5104(e)(1) for possessing firearms on U.S. Capitol Grounds; he appeared pro se and unsuccessfully sought dismissal on Second Amendment and due-process (vagueness/fair-notice) grounds.
Class later pleaded guilty pursuant to a written plea agreement that waived many rights but did not expressly mention waiver of the right to appeal the statute’s constitutionality.
At the Rule 11 colloquy the court advised Class he was giving up his right to appeal; Class pled guilty, was sentenced, and then appealed asserting the same constitutional claims.
The D.C. Circuit held his guilty plea waived those constitutional challenges; the Supreme Court granted certiorari to decide whether a guilty plea by itself bars a direct appeal of the constitutionality of the statute of conviction.
The Supreme Court (majority) held a guilty plea does not, by itself, bar a federal defendant from raising a facial statutory-constitutionality challenge on direct appeal when the claim (if successful) would show the government lacked power to constitutionally prosecute and can be resolved on the existing record.
The Court declined to treat Rule 11(a)(2)’s conditional-plea procedure as exclusive or dispositive because the Advisory Committee expressly stated Rule 11(a)(2) does not apply to Menna–Blackledge-type claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an unconditional guilty plea bars a defendant from directly appealing the constitutionality of the statute of conviction	Class argued a guilty plea does not waive a claim that the State may not constitutionally prosecute him (Second Amendment and due-process vagueness claims)	Government argued a guilty plea inherently waives constitutional challenges unless preserved under Rule 11(a)(2) or expressly reserved	Held: A guilty plea, by itself, does not bar a direct appeal of a facial constitutional challenge to the statute when the claim challenges the government’s power to prosecute and can be decided on the existing record
Whether Rule 11(a)(2) creates the exclusive procedure to preserve constitutional claims after a guilty plea	Class: Rule 11(a)(2) is not exclusive and Advisory Committee notes recognize Menna–Blackledge exceptions	Government: Rule 11(a)(2) requires reservation in writing to preserve waivable claims on appeal; it furthers finality and uniformity	Held: Rule 11(a)(2) is not exclusive; the Advisory Committee expressly said it does not apply to Menna–Blackledge claims, so it cannot resolve this question definitively
Whether Class expressly or implicitly waived his constitutional claims by plea agreement or colloquy	Class: Plea agreement did not expressly waive the right to challenge the statute’s constitutionality; colloquy did not explicitly waive that right either	Government: District court’s plea colloquy statement and plea agreement imply waiver of appeal rights	Held: No express or effective implicit waiver of the constitutional claims; the colloquy did not clearly foreclose the claims and the written plea agreement was silent on them
Whether claims that rely on factual development beyond the record are preserved after a guilty plea	Class: His claims can be resolved on the existing record (court accepted that view)	Government: Some claims (e.g., like in Broce) require facts beyond the record and are foreclosed by plea admissions	Held: Claims that would require contradicting plea admissions or extra-record factual development remain barred; but claims that challenge the State’s authority and are resolvable on the record survive

Key Cases Cited

Haynes v. United States, 390 U.S. 85 (1968) (guilty plea did not waive prior constitutional claim)
Blackledge v. Perry, 417 U.S. 21 (1974) (due-process vindictive-prosecution claim survived guilty plea because it challenged the State’s power to prosecute)
Tollett v. Henderson, 411 U.S. 258 (1973) (guilty plea bars challenges to antecedent trial-related constitutional defects)
Menna v. New York, 423 U.S. 61 (1975) (a plea does not bar a claim that the State may not constitutionally prosecute at all)
United States v. Broce, 488 U.S. 563 (1989) (guilty plea admits factual and legal elements necessary for conviction; claims requiring contradicting the plea or extra-record evidence are barred)
Ruiz v. United States, 536 U.S. 622 (2002) (a valid guilty plea must be voluntary and intelligent; it waives many trial rights)
Vonn v. United States, 535 U.S. 55 (2002) (Advisory Committee notes on Rule 11 are relevant to interpreting the Rule)
Haring v. Prosise, 462 U.S. 306 (1983) (guilty plea renders irrelevant certain pre-plea constitutional claims, such as Fourth Amendment suppression challenges)