A guilty plea waives a Fourth Amendment claim. The plea is the basis of conviction, not the search. United States v. Porter, 2019 U.S. App. LEXIS 22990 (3d Cir. Aug. 1, 2019):
As relevant here, an unconditional “valid guilty plea ‘results in the defendant’s loss of any meaningful opportunity he might otherwise have had to challenge the admissibility of evidence obtained in violation of the Fourth Amendment.'” Id. (quoting Haring v. Prosise, 462 U.S. 306, 320, 103 S. Ct. 2368, 76 L. Ed. 2d 595 (1983)). This rule is founded on the “simpl[e] recogni[tion] that when a defendant is convicted pursuant to his guilty plea rather than a trial, the validity of that conviction cannot be affected by an alleged Fourth Amendment violation because the conviction does not rest in any way on evidence that may have been improperly seized.” Haring, 462 U.S. at 321. Instead, the defendant who pleads guilty “is convicted on his counseled admission in open court that he committed the crime charged against him.” McMann v. Richardson, 397 U.S. 759, 773, 90 S. Ct. 1441, 25 L. Ed. 2d 763 (1970). The basis for Porter’s conviction is thus his solemn and unconditional confession of guilt—not the constitutionality of the search that discovered the cocaine base in his duffel bag.