Class v. United States

Facts of the Case

A federal grand jury indicted petitioner, Rodney Class, for possessing firearms in his locked jeep, which was parked on the grounds of the United States Capitol in Washington, D. C. Appearing pro se, Class asked the District Court to dismiss the indictment. He alleged that the statute, 40 U.S.C.S. § 5104(e), violated the Second Amendment and the Due Process Clause. After the District Court dismissed both claims, Class pleaded guilty to “Possession of a Firearm on U. S. Capitol Grounds, in violation of § 5104(e). A written plea agreement set forth the terms of Class’ guilty plea, including several categories of rights that he agreed to waive. The agreement said nothing about the right to challenge on direct appeal the constitutionality of the statute of conviction. After conducting a hearing pursuant to Fed. R. Crim. P. 11(b), the District Court accepted Class’ guilty plea and sentenced him. Soon thereafter, Class sought to raise his constitutional claims on direct appeal. The Court of Appeals held that Class could not do so because, by pleading guilty, he had waived his constitutional claims. The United States Supreme Court granted Class’ petition for review.

Question

“Can a non-custodial parent invoke ICWA to block an adoption voluntarily and lawfully initiated by a non-Indian parent under state law?Does ICWA define “parent” to include an unwed biological father who has not complied with state law rules to attain legal status as a parent?”

CONCLUSION

“No, a guilty plea alone does not bar a federal criminal defendant from challenging the constitutionality of his conviction. Justice Stephen Breyer delivered the 6-3 majority opinion of the Court. The Court looked at several prior decisions developing its jurisprudence on how a guilty plea affects the constitutional claims available to a criminal defendant, finding a clear doctrine that “a plea of guilty to a charge does not waive a claim that—judged on its face—the charge is one which the State may not constitutionally prosecute.” The Court found that Class had neither expressly nor implicitly waived his constitutional claims by pleading guilty and that Federal Rule of Criminal Procedure 11(a)(2), which governs “conditional” guilty pleas, is inapplicable because the Rule’s drafters specifically stated that the rule “has no application” to the types of constitutional claims raised in this case.Justice Samuel Alito filed a dissenting opinion, in which Justices Anthony Kennedy and Clarence Thomas joined, criticizing the majority for reaching a decision not clearly grounded in the Constitution or other basis, and for failing to clarify the “confusing” doctrine established in prior cases. The dissent looked first to the Constitution and found that it does not prohibit the waiver of rights Class asserted, then found that neither is there a federal statute or rule that bars such waiver. Ultimately, the dissent found that Rule 11 of the Federal Rules of Criminal Procedure should govern the case and thus that an unconditional guilty plea waives all nonjurisdictional claims, except for those specifically described in the prior Court cases on point.”

Case Information

Citation: 583 US (2018)
Granted: Feb 21, 2017
Argued: Oct 4, 2017
Decided: Feb 21, 2018
Case Brief: 2018