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Class v. United States

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Supreme Court of the United States
Class v. United States
Term: 2017
Important Dates
Argument: October 4, 2017
Decided: February 21, 2018
Outcome
D.C. Circuit reversed
Vote
6 - 3 to reverse
Majority
Stephen Breyer • Chief Justice John G. Roberts • Elena Kagan • Neil Gorsuch • Ruth Bader Ginsburg • Sonia Sotomayor
Dissenting
Samuel Alito • Anthony Kennedy • Clarence Thomas


Class v. United States is a case argued during the October 2017 term of the U.S. Supreme Court. Argument in the case was held on October 4, 2017. The case came on a writ of certiorari to the United States Court of Appeals for the District of Columbia Circuit.

The case addressed a split among federal circuit courts on the issue of whether a guilty plea automatically waives a defendant's right to appeal the constitutionality of the statute under which a defendant was convicted. The D.C. Circuit, First Circuit, and Tenth Circuit prohibited a defendant who pleaded guilty from raising challenges on appeal to the constitutionality of the law under which the defendant was convicted. Under Rule 10 of the rules of procedure for the U.S. Supreme Court, the Supreme Court often grants certiorari to resolve differences between circuit courts.

HIGHLIGHTS
  • The case: After pleading guilty to a violation of federal law, Rodney Class sought to bring an appeal challenging the constitutionality of the same law. A three-judge panel of the D.C. Circuit denied Class' appeal, citing a precedent of the court, United States v. Delgado-Garcia, that prohibits such challenges from defendants who pleaded guilty.
  • The issue: Is the D.C. Circuit's rule prohibiting defendants that plead guilty from later raising constitutional challenges to the same law on appeal unconstitutional?
  • The outcome: The U.S. Supreme Court reversed the D.C. Circuit, ruling that a guilty plea does not prohibit a defendant from challenging the constitutionality of the statute under which they were convicted.[1]


    • In brief: Rodney Class pleaded guilty to a violation of federal law in a Washington, D.C., federal district court. Class later appealed his conviction, arguing that the law under which he pleaded guilty was unconstitutional. A three-judge panel of the D.C. Circuit, citing the court's precedent in United States v. Delgado-Garcia, rejected Class' appeal. Under Delgado-Garcia, with only two exceptions, a defendant who pleaded guilty to violating a federal law is prevented from later raising a challenge to the constitutionality of the law on appeal. Not all federal appeals courts, however, treated post-plea constitutional challenges uniformly. Argument in the case was held on October 4, 2017. On February 21, 2018, the Supreme Court reversed the decision of the D.C. Circuit.[1]

    You can review the lower court's opinion here.[2]

    Background

    Rodney Class, the petitioner in this case, accepted a plea agreement and pleaded guilty in federal district court to one count of possession of a firearm on the grounds of the U.S. Capitol, in violation of 40 U.S.C. 5104(e). Class appeared as a pro se defendant at the time of his plea. He had been appointed counsel previously but requested that his appointed counsel be discharged. Still, counsel from the U.S. Public Defender Service (PDS) served as advisory counsel.

    At his plea, Class had the following exchange with the district court:[2]

    “

    THE COURT: If you went to trial and you were convicted, you would have a right to appeal your conviction to the Court of Appeals and to have a lawyer help you prepare your appeal. Do you understand that?
    [APPELLANT]: Yes.
    THE COURT: Do you know what I mean by your right to appeal?
    [APPELLANT]: Yeah. Take it to the next court up.
    THE COURT: All right. Now, by pleading guilty, you would be generally giving up your rights to appeal. Do you understand that?
    [APPELLANT]: Yes.
    THE COURT: Now, there are exceptions to that. You can appeal a conviction after a guilty plea if you believe that your guilty plea was somehow unlawful or involuntary or if there is some other fundamental defect in these guilty-plea proceedings. You may also have a right to appeal your sentence if you think the sentence is illegal. Do you understand those things?
    [APPELLANT]: Yeah. Pretty much.
    THE COURT: Now, if you plead guilty in this case and I accept your guilty plea, you’ll give up all of the rights I just explained to you, aside from the exceptions that I mentioned, because there will not be any trial, and there will probably be no appeal. Do you understand that?
    [APPELLANT]: Yes.[3]

    		”

    After pleading guilty, Class appealed to the United States Court of Appeals for the District of Columbia Circuit on claims of three constitutional errors and one statutory error. A three-judge panel of the circuit court composed of Judges David Sentelle, Sri Srinivasan, and Thomas Griffith heard arguments in the case. On July 5, 2016, the panel issued an unsigned, per curiam opinion that upheld the district court's judgment and denied each of Class' claims.

    A precedent of the D.C. Circuit, United States v. Delgado-Garcia, provides that "[u]nconditional guilty pleas that are knowing and intelligent ... waive the pleading defendant['s] claims of error on appeal, even constitutional claims." The panel acknowledged that while federal rules of criminal procedure permit appeals of specific pretrial motions, Class' plea contained none of these types of claims.

    The panel's opinion presented the specific grounds on which Class appealed and then presented rationale as to why Class' appeal was dismissed. The panel opinion stated,[2]

    “

    The plea agreement included an explicit waiver of appeal rights as to sentencing errors and collateral attacks on the conviction, but not as to alleged errors in the indictment or in proceedings before the sentencing. Appellant apparently believes that the lack of an explicit waiver permits him to proceed in the present appeal. He is in error. The holding from Delgado-Garcia quoted above reflects the universally-recognized law of the United States. ...
    There are two recognized exceptions to this rule: 'the defendant’s claimed right not to be haled into court at all,' and a claim 'that the court below lacked subject-matter jurisdiction over the case.' ... Neither claimed exception applies here.[3]

    		”

    Based on the particulars of Class' appeal, because the claims raised did not fall within the D.C. Circuit's jurisprudence on exceptions to appeal a guilty plea, Class' appeal was dismissed and the district court's judgment was affirmed.

    Petitioner's challenge

    Rodney Class, the petitioner, challenged the holding of the D.C. Circuit. Class argued that the D.C. Circuit's ruling in United States v. Delgado-Garcia violated the U.S. Supreme Court's holding in Blackledge v. Perry, which held that a defendant who pleads guilty can raise any constitutional claim on appeal so long as that claim does not depend on the defendant challenging the defendant's factual guilt.[4]

    Certiorari granted

    On September 30, 2016, Rodney Class, the petitioner, initiated proceedings in the Supreme Court of the United States in filing a petition for a writ of certiorari to the D.C. Circuit. The U.S. Supreme Court granted Class' certiorari request on February 21, 2017. Argument in the case was held on October 4, 2017.[4]

    Question presented

    Question presented:

    "Whether a guilty plea inherently waives a defendant's right to challenge the constitutionality of his statute of conviction?"[4]

    Audio

    • Audio of oral argument:[5]



    Transcript

    • Transcript of oral argument:[6]

    Outcome

    In a six to three ruling, the United States Supreme Court reversed the decision of the D.C. Circuit.[1]

    Majority opinion

    Justice Stephen Breyer authored the majority opinion, joined by Chief Justice John Roberts and Justices Ruth Bader Ginsburg, Sonia Sotomayor, Elena Kagan, and Neil Gorsuch.[1]

    Justice Breyer reviewed Supreme Court caselaw regarding the limitations of guilty pleas. He concluded that prior holdings had established that while a guilty plea limits a defendant's rights to appeal many issues, it does not limit the defendant's right to challenge the statute under which he or she was convicted:

    “ These holdings reflect an understanding of the nature of guilty pleas which, in broad outline, stretches back nearly 150 years. In 1869 Justice Ames wrote for the Supreme Judicial Court of Massachusetts:
    'The plea of guilty is, of course, a confession of all the facts charged in the indictment, and also of the evil intent imputed to the defendant. It is a waiver also of all merely technical and formal objections of which the defendant could have availed himself by any other plea or motion. But if the facts alleged and admitted do not constitute a crime against the laws of the Commonwealth, the defendant is entitled to be discharged.'[1][7][3]
    		 ”

    Class' claims, Breyer continued, "challenge the Government’s power to criminalize Class’ (admitted) conduct. They thereby call into question the Government’s power to ‘constitutionally prosecute’ him. A guilty plea does not bar a direct appeal in these circumstances." He concluded:

    “ A valid guilty plea relinquishes any claim that would contradict the admissions necessarily made upon entry of a voluntary plea of guilty. But the constitutional claim at issue here is consistent with Class’ admission that he engaged in the conduct alleged in the indictment...Class’ challenge does not in any way deny that he engaged in the conduct to which he admitted. Instead..., he seeks to raise a claim which, judged on its face based upon the existing record, would extinguish the government’s power to constitutionally prosecute the defendant if the claim were successful.[1][8][3] ”

    Dissenting opinion

    Justice Samuel Alito dissented, joined by Justices Clarence Thomas and Anthony Kennedy. Justice Alito would have affirmed the holding of the circuit court. Alito criticized the majority opinion, writing that the decision provided "no clear answer" for lower courts. "And to make matters worse," he continued, "the Court also fails to make clear whether its holding is based on the Constitution or some other ground." He concluded:

    “ There is no justification for the muddle left by today’s decision. The question at issue is not conceptually complex. First, the Federal Constitution does not prohibit the waiver of the rights Class asserts. We have held that most personal constitutional rights may be waived...Second, no federal statute or rule bars waiver...I fear that today’s decision will bedevil the lower courts.[1][3] ”

    Text of the opinion

    See also

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 United States Supreme Court, "Class v. United States" Opinion, February 21, 2018
    2. ↑ 2.0 2.1 2.2 U.S. Court of Appeals for the District of Columbia Circuit, United States of America v. Rodney Class, July 5, 2016
    3. ↑ 3.0 3.1 3.2 3.3 3.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    4. ↑ 4.0 4.1 4.2 Supreme Court of the United States, Class v. United States, February 21, 2017
    5. ↑ Supreme Court of the United States, Class v. United States, argued October 4, 2017
    6. ↑ Supreme Court of the United States, Class v. United States, argued October 4, 2017
    7. ↑ Internal citations omitted.
    8. ↑ Internal quotations and citations omitted.
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