Content area
Full Text
Introduction
Plea bargains, in which a defendant pleads guilty to a crime in exchange for a reduced sentence and an opportunity to avoid the uncertainty of a trial, are increasingly common in the criminal justice system.1 Once a defendant accepts a plea bargain, the circuits are split on whether or not the plea inherently waives a defendant's right to challenge her statute of conviction upon appeal.2 The United States Supreme Court will soon provide clarification on this question in Class v. United States.3
The government charged Rodney Class, the petitioner in Class, with "possession of a firearm" on the grounds of the Capitol building.4 Appearing pro se, Class pled guilty to the charge in district court.5 Prior to accepting his plea and "pursuant to Federal Rule of Criminal Procedure 11 ", the district court informed Class that by pleading guilty he would be "generally giving up [his] rights to appeal", except for his right to challenge the voluntariness of the plea and the legality of his sentence.6 Class responded that he understood that he was waiving his appellate rights.7
Despite his response to the district court, Class later appealed, claiming that the statute prohibiting firearms on Capitol grounds was unconstitutional under the Second Amendment.8 The D.C. Circuit Court declined to address the merits of Class' claim.9 Instead, the Court maintained that in only two situations can an unconditional plea waive a defendant's right to appeal her conviction: (1) when she asserts a "claim that the [lower] court lacked. . . jurisdiction", and (2) when she asserts a claim that the state should not have "haled [her] into court at all".10 The Court held that because his claim did not fall into one of those two exceptions, Class had no right to challenge the constitutionality of the statute.11
This comment argues that the D.C. Circuit's conclusion was incorrect, and that the Supreme Court should follow a different approach upon review. Part II explores the Court's limited case law addressing the effects of guilty pleas on challenges to various procedural errors on appeal. Additionally, Part II discusses the robust jurisprudence concerning the retroactive application of substantive criminal rules.12
Part III argues that the retroactivity doctrine cautions against holding that a guilty plea precludes a defendant from challenging...