United States v. John Polhill, 681 F. App'x 292

John Polhill pleaded guilty, per a written agreement, to bank robbery (18 U.S.C. § 2113) and possession/discharge of a firearm in furtherance of a crime of violence (18 U.S.C. § 924(c)), plus aiding and abetting counts.
Six months after his plea, Polhill moved to withdraw it, arguing bank robbery is not a "crime of violence" that can predicate a § 924(c) conviction.
The district court applied the Fourth Circuit's six-factor Moore test for plea-withdrawal motions and denied the motion.
Polhill was sentenced to an aggregate term of 207 months and appealed the denial of his motion to withdraw his plea.
The Fourth Circuit reviewed for abuse of discretion and considered whether bank robbery qualifies as a predicate crime of violence for § 924(c).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Polhill may withdraw his guilty plea before sentencing	Polhill: bank robbery is not a "crime of violence," so his § 924(c) conviction is invalid, supporting withdrawal	Government: Moore factors not satisfied; bank robbery is a crime of violence under the force clause, so plea stands	Denial of motion affirmed — district court did not abuse discretion

United States v. Moore, 931 F.2d 245 (4th Cir. 1991) (sets six-factor test for pre-sentencing plea withdrawal)
United States v. Nicholson, 676 F.3d 376 (4th Cir. 2012) (standard of review for plea-withdrawal denial)
United States v. Thompson-Riviere, 561 F.3d 345 (4th Cir. 2009) (defendant bears burden to justify withdrawal)
United States v. Lambey, 974 F.2d 1389 (4th Cir. 1992) (strong presumption of validity where Rule 11 substantially complied)
United States v. McNeal, 818 F.3d 141 (4th Cir. 2016) (bank robbery under § 2113(a) is a crime of violence under § 924(c) force clause)