Class v. United States: An Imperfect Application of the Menna-Blackledge Doctrine to Post-Guilty Plea Constitutional Claims

Nikolaus Albright

In Class v. United States, the Supreme Court addressed whether an unconditional guilty plea bars a federal criminal defendant from challenging the constitutionality of the statute of conviction on direct appeal. Although an unconditional guilty plea does waive some constitutional claims, the Court ruled that a guilty plea does not waive a defendant’s ability to challenge the constitutionality of the statute of conviction because such a claim falls within the Menna-Blackledge exception. The Court correctly held that the Menna-Blackledge doctrine applies to claims that challenge the constitutionality of the statute of conviction because such claims challenge the government’s power to constitutionally convict a defendant. The Court’s holding is consistent with its ruling in United States v. Broce because Class’s claim did not contradict the conduct admitted in his guilty plea, and the Court’s holding is compatible with Rule 11 of the Federal Rules of Criminal Procedure because the text of the Rule does not require a defendant to reserve a constitutional challenge through a conditional plea. Additionally, the Court’s holding was appropriate because Rule 11(a)(2) alone does not provide adequate procedural safeguards for defendants as they enter their plea, and the Court properly balanced the defendant’s interest in asserting constitutional values and in being free from punishment against the government’s interests in maintaining the finality of convictions and conserving resources. The Court, however, failed to promote uniformity in the federal circuits by not addressing the current circuit split on the issue and by neglecting to adopt a clear rule of law.