Anthony William Goodman v. Commonwealth of Virginia
1037162
| Va. Ct. App. | Jun 27, 2017Background
- Goodman faced multiple charges including murder, attempted murder, robbery, firearms offenses, malicious wounding, and prohibited firearm possession; trial was set for July 1, 2015.
- On the trial date Goodman entered an Alford-type guilty plea to two counts of robbery and one firearm-in-furtherance-of-a-felony count pursuant to a plea agreement.
- The plea agreement contained an express waiver: Goodman knowingly, intelligently, and voluntarily waived the right to withdraw his guilty pleas and to appeal.
- During a detailed plea colloquy the circuit court reviewed the written waiver, and Goodman affirmed he understood and agreed to the waiver and that his pleas were voluntary.
- The Commonwealth nolle prossed the remaining charges, and the court ordered a presentence report and guideline computations.
- Goodman later moved to withdraw his guilty pleas; the circuit court denied the motions relying on this court’s holding in Griffin v. Commonwealth. Goodman appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion by denying motions to withdraw guilty pleas | Goodman argued the court should allow withdrawal despite the written waiver | Commonwealth argued Goodman expressly waived the right to withdraw and the waiver was enforceable | Court held waiver was valid and enforceable; no abuse of discretion in denying withdrawal |
Key Cases Cited
- Griffin v. Commonwealth, 65 Va. App. 714 (Va. Ct. App.) (defendant may expressly waive right to withdraw plea; plea treated as contract)
- Pritchett v. Commonwealth, 61 Va. App. 777 (Va. Ct. App.) (abuse-of-discretion standard for reviewing denial of motion to withdraw plea)
- Hernandez v. Commonwealth, 67 Va. App. 67 (Va. Ct. App.) (abuse-of-discretion review requires case-specific analysis)
- Burke v. Burke, 52 Va. App. 183 (Va. Ct. App.) (waiver enforced if party had knowledge and intended to relinquish right)
- Williams v. Commonwealth, 59 Va. App. 238 (Va. Ct. App.) (standard on when discretion is abused)
- Hoverter v. Commonwealth, 23 Va. App. 454 (Va. Ct. App.) (fact-specific determination of abuse of discretion)
- North Carolina v. Alford, 400 U.S. 25 (U.S. 1970) (recognizing guilty plea while maintaining innocence may be accepted when in defendant’s best interest)