Class v. United States

40

Does a guilty plea inherently waive a defendant’s right to challenge the constitutionality of his conviction?1


  1. We talked about this case in Episode 40. More information about the case can be found here

9-0 Class

9-0 Class

9-0 Class

Notes

The issue in this case is the default effect of a plea bargain—does it waive arguments not expressly agreed to in the plea bargain—as the defendant argues—or does it waive everything bring a case to finality—as the state argues?

Defendant in this case is:

To be frank, Rodney Class appears to be what Second Amendment friends and foes alike might call a gun nut. He allegedly told the FBI after his arrest that he is a “constitutional bounty hunter” who travels around the country with guns and other weapons in order to help enforce federal criminal laws against judges who he believes have acted unlawfully.

The defendant was caught with a lot of guns:

One fine day in May 2013, having parked his car loaded with guns, ammunition, and several knives in a permit-only lot 1,000 feet from the U.S. Capitol, Class walked to visit nearby Senate and House offices.

(Per ScotusBlog). He was charged under 40 U.S.C. § 5104(e)(1)(A)(i), which makes it illegal to “have readily accessible to any individual on the [Capitol] Grounds ... a firearm.”

Class filed motions challenging the law under the Second Amendment, but after he lost, he plead guilty. Now he wants to appeal the denial of the Second Amendment challenge, but the Government says he waived that by entering a non-conditional plea agreement.

Class relies on two cases:

  • Blackledge v. Perry (1974), which holds that vindictive prosecution claims survive a plea agreement.
  • Menna v. New York (1975), which holds that double jeopardy claims survive a plea agreement.

It seems the Courts job in this case is to craft a rule that tells us which claims survive a plea agreement unless expressly waived, and which claims need not be expressly waived in the plea agreement.

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