Whether the courts of appeals have improperly narrowed the 'fair and just reason' standard for evaluating a defendant's request to withdraw a guilty plea

QUESTION PRESENTED FOR REVIEW Whether the courts of appeals, by creating checklists of considerations for the district courts to follow, have improperly narrowed the “fair and just reason” standard that Federal Rule of Criminal Procedure 11(d) sets for evaluating a defendant’s request to withdraw a guilty plea.