## Facts

- A federal grand jury indicted Rodney Class for possessing firearms in his locked Jeep parked on the grounds of the U.S. Capitol, charged under 40 U.S.C. § 5104(e)(1), which prohibits carrying a firearm on Capitol Grounds.
- Proceeding pro se, Class moved to dismiss the indictment, arguing the statute violated the Second Amendment and the Due Process Clause.
- The district court denied the motion to dismiss.
- Class entered an unconditional guilty plea to possession of a firearm on U.S. Capitol Grounds.
- The written plea agreement listed several categories of waived rights but did not mention waiving the right to challenge the constitutionality of the statute of conviction on direct appeal.
- After a Rule 11 plea colloquy, the district court accepted the plea and sentenced Class.
- On direct appeal, Class again raised his constitutional challenges to § 5104(e)(1).
- The D.C. Circuit affirmed, holding the guilty plea waived those constitutional claims.

## Issues

1. Whether an unconditional guilty plea, by itself, bars a federal defendant from raising on direct appeal a constitutional challenge to the statute of conviction.

## Decision

- The Supreme Court reversed and remanded in a 6–3 decision.
- The Court held that a guilty plea, by itself, does not bar a federal criminal defendant from challenging the constitutionality of the statute of conviction on direct appeal.
- The Court concluded Class’s constitutional claims were not waived by the plea because they fell within claims that implicate the government’s authority to prosecute.
- The Court rejected the argument that Rule 11(a)(2) makes a conditional plea the exclusive mechanism to preserve such claims for appeal.

## Legal Principles

- A valid guilty plea generally waives claims that would contradict the admissions necessarily made by entering the plea and many claims tied to pre-plea governmental conduct.
- A guilty plea does not, by itself, waive claims that—on their face—challenge the government’s power to constitutionally prosecute the defendant (including facial challenges to the constitutionality of the statute of conviction).
- Rule 11(a)(2) (conditional pleas) is not an exclusive procedure for preserving on appeal a Menna–Blackledge-type claim that the prosecution itself is constitutionally forbidden.
- A defendant may still lose the ability to raise such claims if they are expressly waived in the plea agreement or during the plea colloquy.

## Conclusion

The Court held that Class’s unconditional guilty plea did not alone prevent him from pursuing on direct appeal a constitutional challenge to the statute under which he was convicted, distinguishing power-to-prosecute claims from waived, case-specific pre-plea challenges.


Class v. United States, 583 U.S. 174 (2018)