Class v. United States

Rodney Class parked his vehicle on the grounds of the United States Capitol in Washington, D.C., with three firearms inside. He was charged under a federal statute prohibiting the possession of weapons on Capitol grounds. Class pleaded guilty unconditionally but subsequently sought to challenge the constitutionality of the statute on appeal, arguing it violated his Second Amendment right to bear arms. The district court and the D.C. Circuit held that his unconditional guilty plea waived any right to contest the statute's validity. The Supreme Court granted certiorari to resolve whether an unconditional guilty plea bars a criminal defendant from challenging the constitutionality of the statute of conviction. The case was argued on February 21, 2018.

In a 6-3 decision authored by Justice Stephen Breyer, the Supreme Court held that an unconditional guilty plea does not waive a defendant's claim that the statute of conviction is unconstitutional. The Court reasoned that such a challenge contests the government's power to criminalize the conduct at all, not merely the defendant's factual guilt. The judgment of the D.C. Circuit was reversed, and the case was remanded for further proceedings to evaluate the Second Amendment claim on its merits.

Whether a criminal defendant's unconditional guilty plea inherently waives the right to challenge the constitutionality of the statute of conviction on direct appeal.

The ruling protects the appellate rights of criminal defendants who plead guilty, ensuring they may still raise fundamental constitutional objections to the laws under which they were convicted. It clarifies that a guilty plea admits factual guilt but does not concede the validity of the criminal statute itself. The decision reinforces the principle that courts should adjudicate constitutional claims on their merits rather than dismissing them on procedural waiver grounds, potentially affecting plea negotiations and the scope of collateral review in federal courts.