Cobbins v. Commonwealth, 668 S.E.2d 816 (Va. Ct. App. 2008). · Go Syfert
Cobbins v. Commonwealth, 668 S.E.2d 816 (Va. Ct. App. 2008). Cases Citing This Book View Copy Cite
“by his own admission, cobbins pled guilty in an attempt to 'buy time' to get what he really wanted: yet another continuance of his trial so he could dismiss his second lawyer and hire a third.”
124 citation events (124 in the last 25 years) across 4 distinct courts.
Strongest positive: Tanya Rashae Holland v. Commonwealth of Virginia (vactapp, 2023-10-24)
Treatment trajectory · 2008 → 2026 · click a year to view as-of
2008 2017 2026
Top citers, strongest first. 41 distinct citers.
discussed Cited as authority (verbatim quote) Tanya Rashae Holland v. Commonwealth of Virginia (2×) also: Cited as authority (rule)
Va. Ct. App. · 2023 · signal: see · quote attribution · 1 verbatim quote · confidence high
by his own admission, cobbins pled guilty in an attempt to 'buy time' to get what he really wanted: yet another continuance of his trial so he could dismiss his second lawyer and hire a third.
cited Cited as authority (rule) Benjamin Scott Legg v. Commonwealth of Virginia
Va. Ct. App. · 2026 · confidence medium
“A reasonable basis must include a proffer of evidence showing a reasonable basis for contesting guilt.” Brown, 297 Va. at 299 (quoting Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008)).
discussed Cited as authority (rule) Rondell Davis v. Commonwealth of Virginia
Va. Ct. App. · 2025 · confidence medium
“A reasonable defense sufficient to withdraw a guilty plea is ‘one based upon a proposition of law or one supported by credible testimony, supported by affidavit.’” Ramsey v. Commonwealth, 65 Va. App. 593, 602 (2015) (quoting Williams, 59 Va. App. at 249 ). “[T]he reasonable defense requirement ‘defeats motions to withdraw which would result in an essentially futile trial[.]’” Hubbard, 60 Va. App. at 208 (quoting Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008)).
cited Cited as authority (rule) Robert Joseph Hardy, II v. Commonwealth of Virginia
Va. Ct. App. · 2025 · confidence medium
The second requirement defeats motions to withdraw which would result in an essentially futile trial.” Brown, 297 Va. at 299 (quoting Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008)).
discussed Cited as authority (rule) Domoniq Zuriel Booker v. Commonwealth of Virginia
Va. Ct. App. · 2024 · confidence medium
“The first requirement protects the integrity of the judicial process by precluding defendants from using a guilty plea as a subterfuge to manipulate the court,” Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008), and it is dispositive here.
discussed Cited as authority (rule) Taejon Lamont Davis v. Commonwealth of Virginia
Va. Ct. App. · 2024 · confidence medium
“The good faith requirement ‘protects the integrity of the judicial process by precluding defendants from using a guilty plea as a subterfuge to manipulate the court . . . .’” Hubbard v. Commonwealth, 60 Va. App. 200, 208 (2012) (quoting Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008)).
discussed Cited as authority (rule) Robert Lee Jeffrey, Jr. v. Commonwealth of Virginia (2×)
Va. Ct. App. · 2023 · confidence medium
Despite the absence of any articulated standard in the statute, it is well -7- settled that to withdraw a guilty plea before sentencing, a defendant must “establish a good-faith basis for making the guilty plea and later seeking to withdraw it, and . . . proffer evidence of a reasonable basis for contesting guilt.” Hernandez v. Commonwealth, 67 Va. App. 67, 75 (2016) (quoting Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008)).
discussed Cited as authority (rule) Daniel A. Martinez-Nolasco v. Commonwealth of Virginia
Va. Ct. App. · 2023 · confidence medium
“The good faith requirement ‘protects the integrity of the judicial process by precluding defendants from using a guilty plea as a subterfuge to manipulate the court . . . .’” Hubbard v. Commonwealth, 60 Va. App. 200, 208 (2012) (quoting Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008)).
discussed Cited as authority (rule) Mark Lshaun Perry Mitchell, s/k/a Mark Lshaun Perry-Mitchell v. Commonwealth of Virginia
Va. Ct. App. · 2023 · confidence medium
As stated previously by this Court, the good faith requirement “protects the integrity of the judicial process by precluding defendants from using a guilty plea as a subterfuge to manipulate the court,” while the reasonable defense requirement “defeats motions to withdraw which would result in an essentially futile trial.” Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008).
discussed Cited as authority (rule) Tony Jacob Thomas v. Commonwealth of Virginia
Va. Ct. App. · 2023 · confidence medium
Code § 19.2-296 provides: A motion to withdraw a plea of guilty or nolo contendere may be made only before sentence is imposed or imposition of a sentence is suspended; but to correct manifest injustice, the court within twenty-one days after entry of a final order may set aside the judgment of conviction and permit the defendant to withdraw his plea. - 13 - In a presentencing motion to withdraw a plea, a defendant must establish two things: (1) “a good-faith basis for making the guilty plea and later seeking to withdraw it,” and (2) “a reasonable basis for contesting guilt.” Hernande…
cited Cited as authority (rule) Destin Dominique Moore v. Commonwealth of Virginia
Va. Ct. App. · 2023 · confidence medium
The second requirement defeats motions to withdraw which would result in an essentially futile trial.” Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008).
cited Cited as authority (rule) Hanger v. Clarke
W.D. Va. · 2023 · confidence medium
Cobbins v. Commonwealth, 668 S.E.2d 816, 820 (Va. Ct. App. 2008).
discussed Cited as authority (rule) Shawn Antoine Keeling v. Commonwealth of Virginia (2×) also: Cited "see"
Va. Ct. App. · 2022 · confidence medium
The second requirement defeats motions to withdraw which would result in an essentially futile trial.” Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008).
discussed Cited as authority (rule) Malik Gary v. Commonwealth of Virginia
Va. Ct. App. · 2022 · confidence medium
The purpose of this requirement is to “protect[] the integrity of the judicial process” by preventing the plea from being used “as a subterfuge to manipulate the court.” Hubbard, 60 Va. App. at 208 (quoting Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008)).
discussed Cited as authority (rule) Youssef Hoballah v. Commonwealth of Virginia
Va. Ct. App. · 2022 · confidence medium
The good faith requirement ‘protects the integrity of the judicial process by precluding defendants from using a guilty plea as a subterfuge to manipulate the court,’ and the reasonable defense requirement ‘defeats motions to withdraw which would result in an essentially futile trial.’” Hubbard v. Commonwealth, 60 Va. App. 200, 208 (2012) (quoting Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008)).
discussed Cited as authority (rule) Ta'Kuan Keontay Bingham, a/k/a Takuan Keontay Bingham v. Commonwealth of Virginia
Va. Ct. App. · 2022 · confidence medium
The second requirement defeats motions to withdraw which would result in an essentially futile trial.” Id. (quoting Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008)). -5- We will assume, without deciding, that Bingham’s motion was made in good faith, and only consider here whether his motion was “premised upon a reasonable basis.” “To establish this basis, the defendant must offer a defense that is ‘substantive’ and ‘reasonable,’ not ‘merely dilatory or formal.’” Spencer v. Commonwealth, 68 Va. App. 183, 187-88 (2017).
discussed Cited as authority (rule) David Joseph Cecil v. Commonwealth of Virginia
Va. Ct. App. · 2022 · confidence medium
“The good faith requirement ‘protects the integrity of the judicial process by precluding defendants from using a guilty plea as a subterfuge to manipulate the court[.]’” Hubbard v. Commonwealth, 60 Va. App. 200, 208 (2012) (quoting Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008)).
cited Cited as authority (rule) Ghyslaine Mendez Belmonte, s/k/a Ghyslaine Mendez-Belmonte v. Commonwealth of Virginia
Va. Ct. App. · 2021 · confidence medium
“A reasonable basis must include a proffer of evidence showing a reasonable basis for contesting guilt.” Id. (quoting Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008)).
cited Cited as authority (rule) Raymond Lamar Washington v. Commonwealth of Virginia
Va. Ct. App. · 2019 · confidence medium
Cobbins v. Commonwealth, 53 Va. App. 28, 34 (2008).
discussed Cited as authority (rule) Franchun Deon Hunt v. Commonwealth of Virginia
Va. Ct. App. · 2018 · confidence medium
To determine whether a motion to withdraw a guilty plea should be granted “requires the defendant (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.” Cobbins v. Commonwealth, 53 Va. App. 28, 34 , 668 S.E.2d 816, 819 (2008).
discussed Cited as authority (rule) Jahsen Heard v. Commonwealth of Virginia
Va. Ct. App. · 2018 · confidence medium
“An ‘Alford plea is a variation of a guilty plea,’” and “has ‘the same preclusive effect as a guilty plea’ for purposes of appeal.” Cobbins v. Commonwealth, 53 Va. App. 28, 36 , 668 S.E.2d 816, 820 (2008) (first quoting United States v. Morrow, 914 F.2d 608, 611 (4th Cir. 1990); then quoting Perry v. Commonwealth, 33 Va. App. 410, 412 , 533 S.E.2d 651, 652 (2000)). -4- sentencing.
discussed Cited as authority (rule) Askia Cuff v. Commonwealth of Virginia
Va. Ct. App. · 2017 · confidence medium
“The good faith requirement ‘protects the integrity of the judicial process by precluding defendants from using a guilty plea as a subterfuge to manipulate - 10 - the court . . . .’” Hubbard v. Commonwealth, 60 Va. App. 200, 208 , 725 S.E.2d 163, 166-67 (2012) (quoting Cobbins v. Commonwealth, 53 Va. App. 28, 34 , 668 S.E.2d 816, 819 (2008)).
cited Cited as authority (rule) Francisco Hernandez, s/k/a Francisco Alberto Hernandez v. Commonwealth of Virginia
Va. Ct. App. · 2016 · confidence medium
Cobbins v. Commonwealth, 53 Va. App. 28, 34 , 668 S.E.2d 816, 819 (2008).
cited Cited as authority (rule) Francisco Hernandez, s/k/a Francisco Alberto Hernandez v. Commonwealth of Virginia
Va. Ct. App. · 2016 · confidence medium
The second requirement defeats motions to withdraw which would result in an essentially futile trial. *76 Cobbins v. Commonwealth, 53 Va.App. 28, 34 , 668 S.E.2d 816, 819 (2008).
discussed Cited as authority (rule) Clayton George Smith v. Commonwealth of Virginia
Va. Ct. App. · 2015 · confidence medium
The good faith requirement ‘protects the integrity of the judicial process by precluding defendants from using a guilty plea as a subterfuge to manipulate the court,’ Cobbins v. Commonwealth, 53 Va.App. 28, 34 , 668 S.E.2d 816, 819 (2008), and the reasonable defense requirement ‘defeats motions to withdraw which would result in an essentially futile trial.’ ” Hubbard, 60 Va.App. at 208 , 725 S.E.2d at 166-67 .
discussed Cited as authority (rule) Matthew Raymond Shropshire v. Commonwealth of Virginia
Va. Ct. App. · 2015 · confidence medium
Accordingly, “[t]he Parris standard . . . requires [a] defendant (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.” Cobbins v. Commonwealth, 53 Va. App. 28, 34 , 668 S.E.2d 816, 819 (2008) (citing Justus, 274 Va. at 155-56 , 645 S.E.2d at 289-90 ).
examined Cited as authority (rule) Marche Tyshon Young v. Commonwealth of Virginia (3×) also: Cited "see"
Va. Ct. App. · 2014 · confidence medium
Cobbins v. Commonwealth, 53 Va. App. 28, 34 , 668 S.E.2d 816, 819 (2008) (citation omitted). -9- The “good faith” prong of the test requires proof that the plea was submitted “under an honest mistake of material fact” or “was induced by fraud, coercion or undue influence and would not otherwise have been made.” Parris, 189 Va. at 324 , 52 S.E.2d at 873 (emphasis added); see Pritchett, 61 Va. App. at 787-90 , 739 S.E.2d at 927-28 .
discussed Cited as authority (rule) Cordaro Rayez Parham v. Commonwealth of Virginia
Va. Ct. App. · 2013 · confidence medium
Accordingly, “[t]he Parris standard . . . requires [a] defendant (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.” Cobbins v. Commonwealth, 53 Va. App. 28, 34-35 , 668 S.E.2d 816, 819 (2008) (citing Justus, 274 Va. at 155-56 , 645 S.E.2d 289 -90).
discussed Cited as authority (rule) Larry Maurice White v. Commonwealth of Virginia
Va. Ct. App. · 2013 · confidence medium
Accordingly, “[t]he Parris standard . . . requires [a] defendant (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.” Cobbins v. Commonwealth, 53 Va. App. 28, 34-35 , 668 S.E.2d 816, 819 (2008) (citing Justus, 274 Va. at 155-56 , 645 S.E.2d 289 -90).
examined Cited as authority (rule) Leonel Alexander Vasquez v. Commonwealth of Virginia (4×) also: Cited "see"
Va. Ct. App. · 2013 · confidence medium
“The good faith requirement ‘protects the integrity of the judicial process by precluding defendants from using a guilty plea as a subterfuge -4- to manipulate the court . . . .’” Hubbard v. Commonwealth, 60 Va. App. 200, 208 , 725 S.E.2d 163, 166-67 (2012) (quoting Cobbins v. Commonwealth, 53 Va. App. 28, 34 , 668 S.E.2d 816, 819 (2008)). “‘A trial court’s finding on the issue of “good faith” is a finding of fact.’” Branch, 60 Va. App. at 547-48 , 729 S.E.2d at 781 (quoting Johnston v. First Union Nat’l Bank, 271 Va. 239, 248 , 624 S.E.2d 10, 15 (2006)).
cited Cited as authority (rule) Commonwealth v. White
Norfolk Cir. Ct. · 2012 · confidence medium
Cobbins v. Commonwealth, 53 Va. App. 28, 34 , 668 S.E.2d 816, 819 (2008).
discussed Cited as authority (rule) Robert Levon Branch v. Commonwealth of Virginia
Va. Ct. App. · 2012 · confidence medium
The good faith requirement ‘protects the integ *547 rity of the judicial process by precluding defendants from using a guilty plea as a subterfuge to manipulate the court,’ and the reasonable defense requirement ‘defeats motions to withdraw which would result in an essentially futile trial.’ ” Hubbard v. Commonwealth, 60 Va.App. 200, 208 , 725 S.E.2d 163, 166-67 (2012) (quoting Cobbins v. Commonwealth, 53 Va.App. 28, 34 , 668 S.E.2d 816, 819 (2008)). 5 There is an important distinction between the record in this case and that in Hubbard .
cited Cited as authority (rule) Orna Lee Terrell v. Commonwealth of Virginia
Va. Ct. App. · 2012 · confidence medium
The second requirement defeats motions to withdraw which would result in an essentially futile trial.” Cobbins v. Commonwealth, 53 Va. App. 28, 34 , 668 S.E.2d 816, 819 (2008).
discussed Cited as authority (rule) Hubbard v. Commonwealth
Va. Ct. App. · 2012 · confidence medium
The good faith requirement “protects the integrity of the judicial process by precluding defendants from using a guilty plea as a subterfuge to manipulate the court,” Cobbins v. Commonwealth, 53 Va.App. 28, 34 , 668 S.E.2d 816, 819 (2008), and the reasonable defense requirement “defeats motions to withdraw which would result in an essentially futile trial,” id.
cited Cited as authority (rule) Hansen Dwayne Fields, Jr. v. Commonwealth of Virginia
Va. Ct. App. · 2012 · confidence medium
The second requirement defeats motions to withdraw which would result in an essentially futile trial.” Id. (quoting Cobbins v. Commonwealth, 53 Va. App. 28, 34 , 668 S.E.2d 816, 819 (2008)).
cited Cited as authority (rule) Williams v. Commonwealth
Va. Ct. App. · 2011 · confidence medium
The second requirement defeats motions to withdraw which would result in an essentially futile trial.” Cobbins v. Commonwealth, 58 Va.App. 28, 34 , 668 S.E.2d 816, 819 (2008).
discussed Cited as authority (rule) Thomas William Stone, Sr. v. Commonwealth of Virginia
Va. Ct. App. · 2011 · confidence medium
“The Parris standard thus requires the defendant (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.” Cobbins v. Commonwealth, 53 Va. App. 28, 34 , 668 S.E.2d 816, 819 (2008) (emphasis added) (citing Justus 5 Code § 19.2-296 provides: A motion to withdraw a plea of guilty or nolo contendere may be made only before sentence is imposed or imposition of a sentence is suspended; but to correct manifest injustice, the court within twenty-one days after entry of a final order ma…
discussed Cited as authority (rule) Keith Lamont Mack v. Commonwealth of Virginia
Va. Ct. App. · 2009 · confidence medium
Subsequent to the decision in Justus, we held that the standard used to determine whether a motion to withdraw a guilty plea should be granted “requires the defendant (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.” Cobbins v. Commonwealth, 53 Va. App. 28, 34 , 668 S.E.2d 816, 819 (2008) (citing Justus, 274 Va. at 155-56 , 645 S.E.2d at 289-90 ).
discussed Cited as authority (rule) Antonio Ewall Thompson v. Commonwealth of Virginia
Va. Ct. App. · 2009 · confidence medium
Subsequent to the decision in Justus, we held that the standard used to determine whether a motion to withdraw a guilty plea should be granted “requires the defendant (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.” Cobbins v. Commonwealth, 53 Va. App. 28, 34 , 668 S.E.2d 816, 819 (2008) (citing Justus, 274 Va. at 155-56 , 645 S.E.2d at 289-90 ).
discussed Cited as authority (rule) Kahihl Leonard Venable v. Commonwealth of Virginia
Va. Ct. App. · 2008 · confidence medium
Cobbins v. Commonwealth, 53 Va. App. 28 , ___, 668 S.E.2d 816, 820 (2008) (citations omitted). -4- consensual encounter “does not require any justification and may be terminated at will by the individual.” White v. Commonwealth, 267 Va. 96, 104 , 591 S.E.2d 662, 666 (2004).
discussed Cited "see" Joshua Barrett Shapiro v. City of Virginia Beach (2×)
Va. Ct. App. · 2010 · signal: see · confidence high
See Cobbins v. Commonwealth, 53 Va. App. 28 , 35 n.3, 668 S.E.2d 816 , 819 n.3 (2008) (citation omitted). 3 See also Williams, 553 U.S. at 304 (noting in the absence of a First Amendment overbreadth challenge, a “plaintiff who engages in some conduct that is clearly proscribed cannot complain of the vagueness of the law as applied to the conduct of others”); Muhammad v. Commonwealth, 269 Va. 451, 501 , 619 S.E.2d 16, 44 (2005); Commonwealth v. Hicks, 267 Va. 573, 580 , 596 S.E.2d 74, 78 (2004); Tjan v. Commonwealth, 46 Va. App. 698, 709 , 621 S.E.2d 669, 674 (2005); Singson v. Commonwealth…
Ronald Patrick COBBINS
v.
COMMONWEALTH of Virginia
1771072.
Court of Appeals of Virginia.
Dec 2, 2008.
668 S.E.2d 816
Melissa Fraser (Gravitt & Gravitt, P.C. on briefs), Halifax, for appellant., Robert H. Anderson, III, Senior Assistant Attorney General (Robert F. McDonnell, Attorney General, on brief), for appellee.
D. Arthur Kelsey.
Cited by 45 opinions  |  Published
D. ARTHUR KELSEY, Judge.

In the trial court, Ronald Patrick Cobbins pled guilty to various offenses and later unsuccessfully sought to withdraw his pleas. He argues on appeal the trial court abused its discretion in denying his motion to withdraw his pleas. Cob-bins also argues the trial court made erroneous rulings prior to his guilty pleas. Because the trial court did not abuse its discretion in denying Cobbins’s motion to withdraw his pleas, we affirm his convictions without addressing his challenge to the trial court’s prior rulings.

I.

In April 2006, the grand jury indicted Cobbins for robbery, use of a firearm during a robbery, malicious discharge of a firearm in an occupied building, and possession of a firearm by a convicted felon. Claiming indigency, Cobbins was appointed counsel. His first attorney quit citing an irreconcilable “personality conflict between defense counsel and the accused” making it impossible for the attorney to fulfill his duties. Cobbins again presented a claim of indigency, and the trial[*32] court appointed substitute counsel. After various continuances, the case was scheduled for a jury trial on February 5, 2007. A few days before trial, Cobbins’s counsel represented to the court that the parties had entered into a written plea agreement and Cobbins wished to address the court prior to signing the agreement. Counsel added that he did not know what Cobbins intended to say. The court took a lengthy recess for counsel and Cobbins to confer.

After the recess, Cobbins stated he wanted to retain private counsel. He recently entered into an agreement to sell his house, Cobbins alleged, and would eventually have enough money to hire counsel. He sought a continuance of the trial date for an indefinite time period to close the house sale and hire new counsel. The court denied the motion to continue.

After again conferring with counsel, Cobbins decided to plead guilty to the charge of possession of a firearm by a convicted felon and to offer Alford guilty pleas to the remaining charges. [1] Cobbins offered the Alford guilty pleas, counsel advised the court, because Cobbins “does not wish to take the chance with a jury trial.”

The trial court conducted the routine colloquy to confirm that Cobbins offered the pleas freely and voluntarily. Cobbins stated he understood “beyond a shadow of a doubt” what he was doing. The prosecutor proffered evidence that Cobbins demanded money from the victim. When she refused, Cob-bins dragged the victim into his bedroom and fired a handgun into the bedroom ceiling. The victim turned over the money[*33] and ran away. Police later arrested Cobbins and found a handgun in his possession, a spent shell casing on his bedroom floor, and a bullet hole in his bedroom ceiling. The prosecutor also proffered Cobbins’s prior felony conviction order.

When the trial court questioned Cobbins about the Alford pleas, Cobbins said he did not “want to take a chance” on a jury trial given his displeasure with counsel and the weight of the evidence against him. The trial court accepted the Alford pleas, ruling that “the evidence as presented by the Commonwealth would be overwhelming and substantially negates the defendant’s claim of innocence” leading Cobbins to rightly conclude “it was in his best interest to enter this Alford plea of guilty.” The trial court entered a conviction order, ordered a presentence report, and scheduled a sentencing hearing.

Shortly thereafter, Cobbins retained private counsel and filed a motion to withdraw his guilty pleas. In support of his motion, Cobbins testified that he entered those pleas because “that was the only way that I felt that I could buy time in order to get a lawyer to try to fight this thing properly.” He was simply “buying time,” Cobbins explained, so he could circuitously get the continuance the trial court had denied him.

Asked about his defense to the charges, Cobbins stated only that some evidence (which he did not disclose) would impeach the victim’s testimony and “other issues” might also help exonerate him. The trial court denied Cobbins’s motion to withdraw his guilty pleas and imposed sentences on his four convictions.

II.

On appeal, Cobbins claims the trial court erred in not allowing him to withdraw his guilty pleas and not granting his earlier motion for a continuance for the purpose of securing private counsel. We hold the trial court did not err in refusing Cobbins’s motion to withdraw his pleas and, consequently, the trial court’s ruling prior to the pleas cannot be appealed.

[*34] A. Motion to Withdraw Guilty Pleas

The Virginia Supreme Court in Parris v. Commonwealth, 189 Va. 321, 52 S.E.2d 872 (1949), made the “seminal statement” of Virginia law governing “the denial by a trial court of a motion to withdraw a guilty plea.” Justus v. Commonwealth, 274 Va. 143, 152, 645 S.E.2d 284, 288 (2007). Parris held that a timely motion should not be denied “if it appears from the surrounding circumstances that the plea of guilty was submitted in good faith under an honest mistake of material fact or facts, or if it was induced by fraud, coercion or undue influence and would not otherwise have been made” so long as “any reasonable ground is offered for going to the jury.” Parris, 189 Va. at 324-25, 52 S.E.2d at 873-74 (emphasis added). To warrant withdrawal of the guilty plea, therefore, the motion must be “made in good faith and sustained by proofs” justifying a trial on the merits. Justus, 274 Va. at 153-54, 645 S.E.2d at 288 (quoting Parris, 189 Va. at 325-26, 52 S.E.2d at 874); Coleman v. Commonwealth, 51 Va.App. 284, 289, 657 S.E.2d 164,166 (2008). [2]

The Parris standard thus requires the defendant (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. Justus, 274 Va. at 155-56, 645 S.E.2d at 289-90. The first requirement protects the integrity of the judicial process by precluding defendants from using a guilty plea as a subterfuge to manipulate the court. The second requirement defeats motions to withdraw which would result in an essentially futile trial. As Parris explained, a trial court’s discretion to grant the motion “will rarely, if[*35] ever, be exercised in aid of an attempt to rely upon a merely dilatory or formal defense.” Justus, 274 Va. at 153, 645 S.E.2d at 288 (quoting Parris, 189 Va. at 323-24, 52 S.E.2d at 873-74). [3]

The decision to allow a defendant to withdraw his guilty plea rests “within the sound discretion of the trial court and is to be determined by the facts and circumstances of each case.” Parris, 189 Va. at 324, 52 S.E.2d at 873. “As in other cases of discretionary power, no general rule can be laid down as to when a defendant will be permitted to withdraw his plea.” Zigta v. Commonwealth, 38 Va.App. 149, 153, 562 S.E.2d 347, 349 (2002) (quoting Parris, 189 Va. at 325, 52 S.E.2d at 874). Appellate review under an abuse-of-discretion standard, “if nothing else, means that the trial judge’s ‘ruling will not be reversed simply because an appellate court disagrees.’” Thomas v. Commonwealth, 44 Va.App. 741, 753, 607 S.E.2d 738, 743 (citation omitted), adopted upon reh’g en banc, 45 Va.App. 811, 613 S.E.2d 870 (2005). “Only when reasonable jurists could not differ can we say an abuse of discretion has occurred.” Tynes v. Commonwealth, 49 Va. App. 17, 21, 635 S.E.2d 688, 689 (2006) (citation omitted).

Applied to this case, these principles support the trial court’s discretionary decision to deny Cobbins’s motion to withdraw his guilty pleas. By his own admission, Cobbins pled guilty in an attempt to “buy time” to get what he really wanted: yet another continuance of his trial so he could dismiss his second lawyer and hire a third. The guilty pleas served as a subterfuge designed to manipulate the court,[*36] against its better judgment, into unwittingly continuing the trial date. Because Cobbins acted in bad faith, he could not justly expect the trial court to reward his duplicitous conduct. The trial court, therefore, did not err in denying his motion to withdraw his pleas. [4]

B. Denial of Motion to Continue

Cobbins argues the trial court violated Code § 19.2-159.1(B) by failing to grant his continuance so that he could secure private counsel. See generally London v. Commonwealth, 49 Va.App. 230, 236, 638 S.E.2d 721, 724 (2006). That issue, however, is not properly before us on appeal.

An “Alford plea is a variation of a guilty plea,” United States v. Morrow, 914 F.2d 608, 611 (4th Cir.1990), and has “the same preclusive effect as a guilty plea” for purposes of appeal, Perry v. Commonwealth, 33 Va.App. 410, 412, 533 S.E.2d 651, 652-53 (2000) (citation omitted); see Clauson v. Commonwealth, 29 Va.App. 282, 294, 511 S.E.2d 449, 455 (1999). Because guilty pleas constitute “a waiver of all defenses other than those jurisdictional,” Savino v. Commonwealth, 239 Va. 534, 539, 391 S.E.2d 276, 278 (1990) (citation omitted), absent a jurisdictional defect, “no appeal will lie because there is nothing to appeal,” Mason v. Commonwealth, 219 Va. 1091, 1098, 254 S.E.2d 116,121 (1979).

Consequently, no appellant can “complain of any non-jurisdictional defects that occurred prior to his guilty plea.” Walton v. Commonwealth, 256 Va. 85, 91, 501 S.E.2d 134, 138 (1998); Terry v. Commonwealth, 30 Va.App. 192, 197, 516[*37] S.E.2d 233, 235-36 (1999) (en banc). We thus decline to decide whether the trial court abused its discretion in denying Cobbins’s motion for a continuance. Cobbins waived appellate review of this issue by pleading guilty to the charge of possession of a firearm by a convicted felon and by offering Alford guilty pleas to the remaining charges.

III.

The trial court did not abuse its discretion in denying Cobbins’s motion to withdraw his guilty pleas. The entry of those pleas precludes Cobbins from challenging the trial court’s earlier denial of his motion for a continuance. For these reasons, we affirm his convictions.

Affirmed.

1

. When offering an Alford plea, a defendant asserts his innocence but admits that sufficient evidence exists to convict him of the offense. See North Carolina v. Alford, 400 U.S. 25, 37-38, 91 S.Ct. 160, 167-68, 27 L.Ed.2d 162 (1970); see also Parson v. Carroll, 272 Va. 560, 565, 636 S.E.2d 452, 454-55 (2006) (describing effect of Alford plea in Virginia). Virginia courts "treat Alford pleas as having the same preclusive effect as a guilty plea.” Perry v. Commonwealth, 33 Va.App. 410, 412, 533 S.E.2d 651, 652 (2000) (citation omitted). As a result, they are often termed " 'Alford[ pleas of guilty.” Malbrough v. Commonwealth, 275 Va. 163, 168, 655 S.E.2d 1, 3 (2008); see also Zigta v. Commonwealth, 38 Va.App. 149, 151, 562 S.E.2d 347, 348 (2002) (using the phrase "Alford plea of guilty”).

2

. Parris does not require a showing that the guilty plea was involuntary in any constitutional sense or the result of ineffective assistance of counsel. As a result, the "presumptions that would favor the Commonwealth in a habeas proceeding” do not apply "when the case remains within the jurisdiction of the trial court to permit the withdrawal of a guilty plea.” Justus, 274 Va. at 154, 645 S.E.2d at 289. For this reason, a good-faith guilty plea could be entered ill-advisedly (but nevertheless voluntarily) and still be a permissible candidate for a motion to withdraw so long as the Parris criteria are satisfied. Id.

3

. Cobbins asserts that requiring him to proffer a reasonable defense in support of a motion to withdraw his pleas violated his "right to due process” under the United States and Virginia Constitutions. See Appellant's Br. at 8. Cobbins, however, never made this argument in the trial court. Rule 5A:18 precludes appellants from raising for the first time on appeal "grounds asserted as a ‘basis for reversal’ of the trial court’s judgment." Blackman v. Commonwealth, 45 Va.App. 633, 642, 613 S.E.2d 460, 465 (2005). Cobbins does not argue that any exception to Rule 5A:18 applies, and we will not invoke one sua sponte. See Edwards v. Commonwealth, 41 Va.App. 752, 761, 589 S.E.2d 444, 448 (2003) (en banc), aff'd by unpublished order, SCV No. 040019 (Va. Oct. 15, 2004).

4

. The Commonwealth also argues Cobbins failed to proffer any “reasonable defense” to the charges, Justus, 274 Va. at 154, 645 S.E.2d at 289, because he presented "no affidavits, alibi witnesses, or even any explanation” in support of his requested not-guilty plea, Coleman, 51 Va.App. at 293, 657 S.E.2d at 168. We need not address this issue, however, because Cobbins fails to satisfy the threshold good-faith requirement under Parris. "In this case, as in all others, we seek to decide cases ‘on the best and narrowest ground available’ from the record.” Kirby v. Commonwealth, 50 Va.App. 691, 698 n. 2, 653 S.E.2d 600, 603 n. 2 (2007) (citations omitted).