David Joseph Cecil v. Commonwealth of Virginia, 0448213

David Cecil pleaded guilty pursuant to a written plea agreement to armed burglary, attempted robbery, conspiracies to commit robbery and burglary, and possession of a firearm after a felony; several firearm-related charges were nolle prossed.
At the plea colloquy Cecil acknowledged understanding the charges, consequences, defenses, and that his plea was voluntary; the circuit court accepted the pleas as knowing and voluntary.
The factual stipulation: Cecil organized and led a group to forcibly enter a residence to steal drugs/money; a shoot-out occurred, Dakota Bailey was killed, and Cecil was wounded.
About a year later Cecil moved pre-sentence to withdraw his pleas, claiming long-standing mental-health problems, lack of understanding when he pled, and a desire to pursue an insanity defense; the court ordered competency evaluation.
A forensic evaluation found Cecil incompetent for a time; he was later restored to competency. At the withdrawal hearing Cecil testified he did not recall entering the pleas and could not remember discussing an insanity defense.
The circuit court denied the motion, finding (1) Cecil failed to demonstrate manifest injustice or lack of a knowing, voluntary plea and (2) Cecil failed to proffer a prima facie, reasonable insanity defense. The Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether circuit court erred denying pre-sentence motion to withdraw guilty pleas	Cecil: plea was not knowing/voluntary due to mental-health issues; motion made in good faith	Commonwealth: colloquy and plea agreement show pleas were knowing, voluntary; no good-faith basis shown	Affirmed — appellant failed to show good faith; court did not abuse discretion
Whether Cecil proffered a reasonable defense (insanity) to justify withdrawal	Cecil: recent incompetency and mental-health history support an insanity defense sufficient to withdraw pleas	Commonwealth: competency to proceed is distinct from legal insanity; Cecil offered no evidence of insanity at time of offense	Affirmed — no prima facie evidence of legal insanity; withdrawal properly denied

Bottoms v. Commonwealth, 281 Va. 23 (Va. 2011) (grounds for pre-sentencing withdrawal: mistake, involuntariness, misconception, fear, fraud, official misrepresentation, or reasonable ground to go to jury)
Branch v. Commonwealth, 60 Va. App. 540 (Va. Ct. App. 2012) (two-part test for pre-sentence withdrawal: good faith and reasonable defense)
Hernandez v. Commonwealth, 67 Va. App. 67 (Va. Ct. App. 2016) (trial court may not weigh credibility when defendant proffers evidence of insanity; such proof can establish a reasonable defense)
Williams v. Commonwealth, 59 Va. App. 238 (Va. Ct. App. 2011) (good-faith requirement explained for plea-withdrawal motions)
Spencer v. Commonwealth, 68 Va. App. 183 (Va. Ct. App. 2017) (standard of review: abuse of discretion for denial of plea-withdrawal motion)
Godinez v. Moran, 509 U.S. 389 (U.S. 1993) (competency to stand trial focuses on present ability to consult with counsel and understand proceedings)
White v. Commonwealth, 272 Va. 619 (Va. 2006) (M'Naghten test explained for legal insanity)