Williams v. Commonwealth
59 Va. App. 238
| Va. Ct. App. | 2011Background
- Defendant was indicted for abduction with intent to defile (Va. Code § 18.2-48).
- In a separate case, another Fairfax conviction included rape and sodomy with concurrent life sentences and nine years.
- Defendant accepted a plea deal: Alford plea to Abduction, 15 years active, to run concurrent with FE-2009-1046; he waived a jury trial.
- Plea colloquy occurred on June 23, 2010; court found the evidence substantial and overwhelming supporting guilt.
- Three weeks later, defendant moved to withdraw his guilty plea claiming he was in shock and fearful of sentencing; the court denied the motion and imposed 40 years with 25 suspended, concurrent with the earlier case.
- This appeal challenges the denial of the withdrawal motion, arguing lack of good faith basis and presence of a reasonable defense to contest guilt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion in denying the motion to withdraw the plea. | Parris standards require good-faith basis and a reasonable basis to contest guilt. | Defendant was in fear and shock and had a potential defense to contest guilt. | No abuse of discretion; proper denial under Parris and Justus; no reasonable basis to withdraw. |
Key Cases Cited
- Parris v. Commonwealth, 189 Va. 321 (1949) (establishes good-faith and reasonable-ground requirements to withdraw a guilty plea)
- Justus v. Commonwealth, 274 Va. 143 (2007) (clarifies standard for withdrawal governed by Parris and limits on broad remand)
- Cobbins v. Commonwealth, 53 Va.App. 28 (2008) (discretionary test and futility consideration for withdrawal motions)
- Coleman v. Commonwealth, 51 Va.App. 284 (2008) (fear of life sentence not alone sufficient; must be good faith basis and credible defense)
- North Carolina v. Alford, 400 U.S. 25 (1970) (defines voluntary and intelligent choice standard for Alford pleas)
- Parsons v. Carroll, 272 Va. 560 (2006) (describes treatment of Alford pleas in Virginia)
- North Carolina v. Alford, 400 U.S. 25 (1970) (voluntariness of Alford plea in context of plea withdrawals)