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Criminal Law: Post-Conviction Relief-Ineffective Assistance of Counsel

Staff Report//April 16, 2026//

Criminal Law: Post-Conviction Relief-Ineffective Assistance of Counsel

Staff Report//April 16, 2026//

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Defendant appealed the denial of his motion for post-conviction relief alleging that trial counsel was ineffective for unreasonably inducing defendant to waive his right to testify.

Where trial counsel’s advice not to testify constituted reasonable strategy and where the record demonstrated that defendant made a knowing and voluntary waiver of his right to testify, the trial court correctly denied defendant’s motion for post-conviction relief.

Judgment is affirmed.

Bateman v. State (MLW No. 84622/Case No. ED113759 – 10 pages) (Missouri Court of Appeals, Eastern District, Lay, J.) Appealed from circuit court, City of St. Louis, Connolly, J. (Gwenda R. Robinson for appellant) (Julia E. Rives for respondent)

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