Criminal – Defendant’s request to withdraw guilty plea is denied

Where the defendant pleaded guilty to second-degree murder and another charge, the circuit court did not err in denying his subsequent motion to withdraw that plea. He did not establish a good-faith basis for making the guilty plea and later seeking to withdraw it, nor did he proffer evidence of a reasonable basis for contesting guilt.

Background

Michael Antonio Hill pleaded guilty to second-degree murder and guilty to stabbing, cutting or wounding another during the commission of a felony. Before sentencing, Hill moved to withdraw his guilty plea. After a hearing, the trial court denied his motion and imposed a sentence.

Standard

The defendant is required “(i) to establish a good-faith basis for making the guilty plea and later seeking to withdraw it, and (ii) to proffer evidence of a reasonable basis for contesting guilt.”

Analysis

The evidence at trial indicated that Hill and Shannon Holland, his girlfriend, each had concerns about the other’s relationship with Rufus Norcross, the victim, and that Hill owed Holland money. By his own admission, Hill went to Holland’s apartment in the middle of the night to “clear the air.”

While there, the two men argued and Hill grabbed his knife from his pocket. During the exchange, Hill admitted to stabbing Holland repeatedly with the knife before leaving the apartment in disarray, while covered in Holland’s blood. Holland’s injuries were extensive and proved fatal. When Hill entered his guilty plea, he conceded that the evidence was sufficient to prove he murdered Holland, and he testified at the hearing on his motion to withdraw his guilty plea that he only pleaded guilty after hearing the evidence and seeing “all the gore” at trial.

Hill told the trial court that he had discussed the nature of the charges, the elements of each offense and the ranges of punishment facing him with his attorney, and he affirmed that he fully understood the potential consequences of entering his plea. Hill then admitted that he decided for himself to plead guilty and agreed that he was waiving his trial and appellate rights. Thus, Hill confirmed in his plea colloquy that he knowingly, voluntarily and intelligently pleaded guilty with full knowledge of the charges and the potential range of punishment confronting him.

As a result, Hill’s apparent claim that his guilty plea was procured inadvisedly or mistakenly is not supported by the record, and the trial court did not abuse its discretion in finding that Hill failed to make his motion in good faith.

The record also does not support Hill’s argument that he acted in self-defense. In the video of Hill’s interview with the officers, which was entered into evidence at the trial, Hill explained that he went to Holland’s apartment, uninvited with a knife in his pocket, in the middle of the night to “clear the air” because Holland was “talking mad trash” about him. Hill testified that he struck Holland first.

The evidence presented at trial demonstrated a protracted and violent physical altercation that left Holland dead with 36 knife wounds to his body. The apartment was in disarray and Holland’s blood was smeared in various places inside the apartment and on the front entrance. Even by his own evidence, Hill did not retreat or seek peace before stabbing Holland to death.

Then, rather than calling the police, Hill removed the Ring camera to avoid detection and fled the scene. Thus, the trial court did not err in finding that Hill did not provide proof of a substantial and reasonable defense to the charges of murder and stabbing during the commission of murder, and this court has no doubt that Hill’s asserted defense would have proven futile at trial as Hill did not act in self-defense.

Moreover, if the trial court had allowed Hill to withdraw his guilty plea, the Commonwealth would have suffered prejudice. The murder took place in June 2022, and Hill’s jury trial commenced on April 29, 2024. The Commonwealth called 16 witnesses in its case-in-chief, all of whom would have had to have appeared again to testify.

A new panel of jurors would also have had to have been chosen, resulting in further delays and significant expenditure of the Commonwealth’s resources. Hill moved to enter his guilty plea after the Commonwealth rested its case, which would have given him an unfair advantage during a retrial and, as the trial court noted, jeopardy had already attached.
Affirmed.

Hill v. Commonwealth, Record No. 1840-24-4, May 12, 2026. CAV (unpublished opinion) (per curiam). From the Circuit Court of Frederick County (Eldridge IV). (Jason E. Ransom; Ransom/Silvester, PLC, on brief), for appellant. Appellant submitting on brief. (Jason S. Miyares, Attorney General; Allison M. Mentch, Assistant Attorney General, on brief), for appellee. VLW 026-7-190. 13 pp.

Full-Text Opinion
VLW 026-7-190