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Essay: Class v. United States, 583 U.S.

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  • Class v. United States, 583 U.S.
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The Case

On May 20, 2013, Rodney Class parked his Jeep on the Capitol grounds in Washington, D.C. Class happened to be keeping guns and ammunition—for which he had legal permits—inside the Jeep. While Class was visiting the Capitol buildings, a policeman spotted a blade and gun holster in Class’ Jeep, after noticing that the Jeep had no required parking permit. After taking Class to Capitol Police headquarters and obtaining a search warrant, police found three guns and ammunition in the Jeep. A grand jury indicted Class on September 3, 2013, for violating the statute which “prohibits any individual from carrying or having accessible to them a firearm on Capitol Grounds or in any Capitol Building” (Titcomb and Belinskiy, law.cornell.edu). Choosing to represent himself, Class raised the claim that the statute contravenes individuals’ Second Amendment right. The court ultimately rejected all of Class’ motions, holding that “weapons should presumptively be banned from a government parking lot, like from a government building” (Ibid.). After failing to appear at trial, Class pled guilty to the accusation. On November 21, 2014, during Class’ Plea Hearing, the District Court notified Class that pleading guilty would waive all of his rights to an appeal except for the ability to appeal if his guilty plea was illicit or involuntary, or if it was shown that the guilty-plea proceedings had essential defects. Class was convicted after consenting to these terms.

Focusing on the violation of his Second Amendment rights, Class appealed to the D.C. court four days later. The government held that Class’ right to challenge the constitutionality of the statute was inherently waived when he pled guilty. Citing the Blackledge and Menna cases, Class rejected the government’s argument by citing the Blackledge v. Perry and Menna v. New York cases—in which the Supreme Court held that constitutional challenge claims do not question the fairness of the trial. The Circuit Court agreed with the government’s argument and maintained that Class’ claims were not properly before the court. Class appealed, and the Supreme Court permitted certiorari to decide “whether [the] petitioner is entitled to challenge the constitutionality of his statute of conviction on appeal, notwithstanding his entry of an unconditional guilty plea in which he did not seek to preserve any right to pursue such a challenge” (Ibid.).

The question the case raises is as follows: Is a defendant’s right to challenge the constitutionality of the statute underlying his/her conviction inherently waived by a guilty plea? By ruling in this case, the Supreme Court will be able to elucidate the appellate rights of defendants in criminal cases who want to dispute the constitutionality of their statute of conviction after pleading guilty. There have been division among circuit courts on this subject. To clarify, Class is not challenging his guilt of committing the crime at hand, nor is he disputing whether the U.S. government thoroughly and fairly proved every component of the crime; he is challenging the constitutionality of the statute of conviction, itself. The United States refutes Class’ argument by contesting that, unless it is explicitly stated otherwise in the plea agreement, a guilty plea inherently waives a defendant’s right to challenge the constitutionality of his/her statue of conviction.

Relation to Class

Autonomy

The principle of autonomy can be observed in Class’ ability to carry guns and ammunition. He is an autonomous individual who has the ability to carry deadly weapons without causing harm to anyone else; however, this notion of Class’ autonomy is complicated when he brings the guns and ammunition on Capitol grounds, where it is illegal to do so.

Equality

One aspect of equality can be seen in Class’ ability to raise a constitutional challenge as a convicted criminal. If he is not allowed to the challenge the constitutionality of his statute of conviction, then he would lose a right that others—those who have not been convicted under the same criminal law—have. His rights, in this specific aspect, would be unequal to others. This analysis, however, is not relevant or appropriate enough to have ground in an argument for or against Class.

The Traditional Liberal View (The Harm Principle & The Offense Principle)

Both the Harm Principle and the Offense Principle cannot essentially be applied to this case.

The Traditional Liberal View (Freedom of Expression)

In John Stuart Mill’s Traditional Liberal View, the restriction of freedom of speech, expression, and opinion can hinder the progression of society’s collective ideas and beliefs. Allowing an individual to express his/her controversial opinion, particularly one that challenges a popular societal belief/view, is beneficial to society because it allows the proponents of a popular belief to either rethink their views, possibly altering them, or reaffirm them by rigorously contesting with the opposing viewpoint. The conflicting beliefs that are added to the “marketplace of ideas” increase the knowledge of society and progresses societal beliefs. Those whose beliefs have changed as a result have, in essence, unlearned a possibly problematic viewpoint; and those who have reaffirmed their beliefs now have a better understanding and appreciation of their viewpoint. This liberal concept can be applied to legal challenges of the constitutionality of statutes. If those convicted of criminal offenses are not able to legally challenge their statute of conviction, within reasonable means, then the government, and the proponents of its views, would not have a way to reinforce the legitimacy of the statute. This can be applied to Class’ case.

Legal Moralism

Notions of legal moralism are not observed in the Class case.

Bad Samaritan Laws

This case does not address any issue regarding an individual being a Bad Samaritan.

Obscene Speech

There is no issue of obscenity of speech in this case

Resolution

I disagree with the United States and contend that not allowing Class to formulate a constitutional challenge because of his guilty plea will hinder the progression and/or reaffirming of societal values and legal statutes. This disagreement largely stems from notions within Millian liberalism. One of the government’s main responses to one of the claims made by those in support of Class—that it is crucial for defendants to be permitted to challenge the constitutionality of their statute of conviction, even after pleading guilty, because of the predominance of plea bargaining in the criminal justice system—is that “Class is undermining the plea system by attempting to gain benefits from two mutually exclusive choices—taking a plea bargain and challenging his conviction” (Ibid.). The government contends that enabling such a strategy would impede plead bargaining’s efficiency goals and “contradict the ‘core promise’ of defendants’ guilty pleas” (Ibid.). The government differentiates Class’ case from Blackledge and Menna by indicating that in those cases guilty pleas were rendered meaningless—by the relevant argument that the court should have never received the cases—because there were already existing legal doctrines that supported the argument that a court should have never been presented with the cases. The government notes, in contrast to the two cases mentioned, that the statute that is being challenged by Class’ appeal is already constitutional. The government “emphasizes that allowing such an appeal after a guilty plea would disrupt the plea system by contradicting the inherent finality of a guilty plea on the issues and factual guilt” (Ibid.). If it is ruled that Class cannot raise a constitutional challenge, then the government, and proponents of the government’s viewpoint, will be missing out on an opportunity to reaffirm the constitutionality of the statue of conviction if the statute is, indeed, constitutional.

The government, if Class is able to raise a constitutional challenge, will be able to reinforce why not permitting citizens to carry guns and ammunition on Capitol grounds is constitutional. This specific statute seems intuitively constitutional; however, under Millian liberalism, if a view—in this case, a statute—is not contested, its proponents will have a lukewarm understanding of why the view is important and needs to be upheld. Now, a reasonable argument, one that is held by the government, against allowing Class to raise a constitutional challenge is that he pled guilty to the allegations against him, which waives his right to challenge the fairness of the of the trial, possibly including his right to challenge the statute at hand. I argue that Class’ guilty plea provides an even greater reason to allow him to challenge the statute.
Mill expresses that those beliefs that are rigorously contested, and then reaffirmed, will further stand more opposition than those beliefs that are not opposed or slightly contested. One could say that any individual other than someone who was convicted of a criminal offense can challenge the constitutionality of a statute, so a defendants’ right to raise a constitutional challenge should still be waived. But if any one individual could raise a significant conjecture against the constitutionality of a statute, it would be the person who is being convicted under that statute. After going through court proceedings and reviewing their statute of accusation to avoid conviction, the defendant would most likely be able to put forth very relevant and cogent objections to said statute’s constitutionality and/or legitimacy. Their sentiments against the constitutionality of a statute will most likely be more sound and significant than those of a random citizen who also questions the legitimacy of the statute. The government would then have to provide a more clear and firm rebuttal against the defendants’ opposition; thus, a more rigorous discussion about the constitutionality of the statute takes place. Allowing Class to raise a constitutional challenge would provide the government the opportunity to rigorously defend the constitutionality of Class’ statute of conviction, further reaffirming the reasons why they statute was put in place.

Allowing Class to challenge the constitutionality of his statute of conviction will also affect many other individuals who have pleaded guilty in criminal cases. The Supreme Court, with its pending decision, “will determine the constitutional rights of all criminal defendants who plead guilty and likely impact the role guilty pleas play in United States jurisprudence” (Ibid.). There have been many cases in which the law under which an individual has been convicted by guilty plea is indeed constitutional. There are also guilty plea cases where the law at hand is questionably constitutional. The Supreme Court should grant Class the right to raise a constitutional challenge because it would grant other guilty plea convicted persons this right, as well. This will not undermine the plea-bargaining system, but would allow those statutes that are constitutional to be reaffirmed, and those that are not truly constitutional would possibly be altered or rescinded.

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