State v. Whitehurst, ___ N.C. App. ___, 800 S.E.2d 671 (May. 2, 2017)

The trial court did not err by denying the defendant’s motion to withdraw his Alford plea. After finding that there was no support in the record for various factual assertions made by the defendant on appeal, the court found that the defendant had offered no fair and just reason for withdrawal of his plea. Among other things, the court rejected the defendant’s argument that he entered his plea while under duress because he was in custody at the time, holding: “Defendant cites no authority for the proposition that the fact that a defendant is incarcerated is per se evidence of coercion, and we decline to adopt the position proposed by defendant.”