Appellate Plea Waiver in Federal Criminal Appeals

The Supreme Court of the United States recently ruled in favor of an appeal for a bounty hunter who pled guilty to a gun possession crime but then attempted to appeal the constitutionality of the violation with which he was charged. In many cases, however, a guilty plea agreement waives a person’s right to an appeal. In this case, though, the direct constitutional appeal was not specifically among the claims that the defendant waived his right to appeal. The Supreme Court ultimately ruled that the man was able to continue with his appeal.

How the Case Came to the Supreme Court

The case arose from Rodney Class, who is a gun rights activist and a veteran with a concealed-carry permit. Class has not threatened anyone with his firearms but brings them with him as he intervenes with judges whom he believes fail to uphold their duties. In 2013, Class went to Washington D.C. to convince Congress to declare him a “constitutional bounty hunter.” After parking his vehicle in a Capitol Hill parking lot, law enforcement saw a knife and empty gun holster in Class’s vehicle.

After searching the vehicle, law enforcement discovered multiple knives and three firearms. Class was then charged with possession of a firearm, which is classified as a federal crime. Class acknowledged his behavior and pled guilty to the offense. Before appealing to the Supreme Court, the District of Columbia and appellate courts ruled that Class’s guilty plea prohibited him from making an appeal.

The Supreme Court’s Opinion

In an opinion of six to three, the Supreme Court of the United States ruled in the reverse of the District of Columbia circuit court. The majority opinion was written by Justice Breyer and held that a guilty plea does not prohibit a defendant from raising an appeal. This argument was based on constitutional grounds and reviewed previous Supreme Court cases concerning the limitations of guilty pleas. This opinion found that prior holdings established that a guilty plea does not limit the defendant’s right to challenge the statute under which he or she was convicted. If the facts alleged do not constitute a crime, the opinion argues, then the defendant is entitled to a discharge. As a result, the majority opinion argues that guilty pleas do not prohibit a direct appeal in Class’s situation.

Justice Alito, joined by Justice Thomas and Justice Kennedy, criticized the majority for reaching a decision that lacked any clear basis in the Constitution.

Obtain the Assistance of a Seasoned Attorney

For many decades, lower federal courts have held that by pleading guilty, a criminal defendant waives his or her right to raise many substantive and procedural claims. As a result, the decision in Class will likely change how a large number of federal criminal appeals are handled. If you need assistance with creating a strong appeal in a federal criminal law case, you need strong and knowledgeable legal counsel. Contact the Federal Criminal Law Center today for assistance in making sure that you have the strongest appeal possible.