A guilty plea, by itself, does not bar a criminal defendant from later appealing his conviction on the ground that the statute of conviction violates the Constitution. In 2013, a federal grand jury indicted Class for possessing a gun in his locked vehicle, which was park on the grounds of the U.S. Capitol. (40 U.S.C. § 5104(e)(1).) He unsuccessfully moved to dismiss the indictment on the grounds the statute violated the Second Amendment and he was denied fair notice that weapons were banned in the parking lot. He then entered a guilty plea, which waived certain rights and preserved others, but said nothing about the right to appeal his constitutional claim. Class appealed his conviction. The Court of Appeals concluded his guilty plea waived the constitutional claim. His petition for writ of certiorari was granted. Held: Reversed. A guilty plea does not relinquish a criminal defendant’s right to claim that the statute of conviction is unconstitutional. (Haynes v. U.S. (1968) 390 U.S. 85.) A guilty plea bars appeal of many claims, including some antecedent constitutional violations related to events that occurred prior to the plea. However, a guilty plea does not waive a claim thatjudged on its facethe charge is one which the State may not constitutionally prosecute (Manna v. New York (1975) 423 U.S. 61 [double jeopardy]). Class’s constitutional claims do not contradict the terms of the indictment or the plea and are consistent with an admission that he did what the indictment alleged. They can be resolved without any need to stray beyond the record. His claims challenge the Government’s power to criminalize Class’s conduct and the power of the Government to constitutionally prosecute him. A guilty plea does not bar a direct appeal under these circumstances.
The full opinion is available on the court’s website here: https://www.supremecourt.gov/opinions/17pdf/16-424_g2bh.pdf