Brown v. Commonwealth

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the circuit court refusing to set aside Defendant's guilty plea, holding that the court of appeals did not abuse its discretion in denying Defendant's motion to withdraw her guilty plea.Defendant pled guilty to petit larceny. Before the circuit court entered the final sentencing order, Defendant filed a motion to withdraw her guilty plea. The circuit court denied the motion and entered the final sentencing order. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the "manifest injustice" standard governs a motion to withdraw a guilty plea made after sentence was pronounced but before the sentencing order was entered; and (2) the grounds Defendant advanced to withdraw her guilty plea did not warrant vacating the guilty plea under the post-sentencing "manifest injustice" standard. View "Brown v. Commonwealth" on Justia Law