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Criminal Law: Post-Conviction Relief-Untimely Motion
Staff Report//April 16, 2026//
Defendant appealed the denial of his motion for post-conviction relief. Appointed counsel failed to file a timely amended motion and the trial court did not conduct an abandonment inquiry.
Where Missouri law required the trial court to conduct a meaningful independent abandonment inquiry, the court was constrained to reverse and remand for further proceedings.
Judgment is reversed and remanded.
Bauer v. State (MLW No. 84626/Case No. SD38925 – 13 pages) (Missouri Court of Appeals, Southern District, Growcock, J.) Appealed from circuit court, Ozark County, Bock, J. (Christian Lehmber, Columbia for appellant) (Julia Rives, Jefferson City for respondent)
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