Judge Sullivan has some questions about Mike Flynn's request to withdraw his guilty plea, including whether Flynn should now be questioned, "under oath, subject to cross-examination" about why the court should allow him to do that. 
Sullivan cites a D.C. Cir. case involving a man who tried to withdraw his plea before sentencing because he said he was pressured into making it. The district judge had a hearing, had the guy testify, and ruled there wasn't a basis for withdrawal. Circuit court affirmed.
The D.C. Cir. held that the most important question in whether a defendant can withdraw his plea is whether it was properly entered in the first place. Could be challenging for Flynn, who entered his guilty plea not once but twice.
Here's that case. Basically, the D.C. Cir. upheld a district court's decision that a defendant who broadly proclaimed his innocence and said he was pressured into pleading guilty couldn't withdraw his guilty plea.
scholar.google.com/scholar_case?c…
scholar.google.com/scholar_case?c…
