In 2013, District of Columbia police discovered several firearms in a Jeep parked legally near the Capitol Building. The owner of the Jeep, Rodney Class, had proper permits and documentation for each firearm in the vehicle, but he was arrested and charged under 40 U.S.C. § 5104(e), which prohibits possession of firearms on the grounds of the Capitol. Class, representing himself, then pleaded guilty to the offense in D.C. Federal District Court. At that point, Class was informed by the court that doing so would waive his right to an appeal, even on constitutional grounds. Not long after, though, Class appealed his conviction to the D.C. Circuit on the grounds that his Second Amendment rights were violated. Class argued before the Circuit Court that a criminal defendant had the right to an appeal on constitutional grounds, citing Blackledge v. Perry and Menna v. New York, two other cases which concern the right to an appeal in face of unlawful prosecution. The Circuit ruled in favor of the government, denying Class’ appeal. However, the Supreme Court granted Class a writ of certiorari in February of 2017.
Arguments were held before the Court during the October 2017 term, yielding surprising results. The defense’s grounds for appeal, as stated in the earlier arguments at the Circuit, were underpinned by the concept that by waiving his right to an appeal under federal statute, Class did not waive his right to appeal on constitutional grounds. The State contended that per the federal rules of criminal procedure, Class had waived his right. During the oral arguments, Justice Breyer proposed a particularly important point: it is more reasonable to only disallow constitutional appeals after a guilty plea in special circumstances, rather than dismissing any appeal after entering a guilty plea. In further arguments, Justice Sotomayor challenged the prosecution’s notion that the state should have reasonable expectations that a case be completely resolved once a guilty plea is entered. Lastly, Ms. Amunson, counsel for Class, argued that the prosecution made no deal specifying that the defendant had waived his right to an appeal, and therefore was within his rights to appeal his conviction.
The decision revealed in February of 2018 was 6-3, overturning the ruling of the District and Circuit courts. Justices Kagan, Ginsburg, Gorsuch, Sotomayor and Chief Justice Roberts ruled together, the opinion of the court delivered by Justice Breyer. The opinion held firmly, according to Supreme Court precedent, that a defendant has the right to appeal conviction on grounds of unconstitutionality regardless of a guilty plea should prosecution be unlawful in the first place. In Class’ case specifically, this would imply that though he pleaded guilty, he should never have been charged on Second Amendment grounds. Therefore in the circumstances of Class’ guilty plea, “Class’ acquiescence neither expressly nor implicitly waived his right to appeal his constitutional claims”. In Justice Alito’s dissenting opinion, he picked apart the majority’s use of Blackledge v. Perry, arguing its specific tenets do not apply to Class. Justice Alito also criticized the lack of actual constitutional grounds for the majority ruling. He also made a practical argument, citing that ninety-five percent of cases in US courts end with plea deals, implying that such a precedent could be dangerous to the system, likely causing potential caseload backups, and further delays in an already strained system.
Class may serve as an important precedent going forward. The idea that a defendant can appeal a guilty plea should benefit those pleading guilty under pressure from prosecution, lacking the money for a protracted court battle. In many cases, a defendant who may not have committed any crimes with which he has been charged will plead guilty to solicit a plea bargain, because he might not be able to afford bail or a competent attorney. In all, the Class ruling should have a profound effect on future cases pertaining to appeals made on constitutional grounds.