DAVID WILLIAM RECTOR, JR. v. STATE OF MISSOURI, SD36895

Rector was convicted by a jury of multiple counts of forgery based on two Comcheck images the store received from its bank.
At trial the State introduced copies of the checks (State's Exhibits 3 and 4); Rector objected to authentication and compliance with bank-record rules.
The trial court admitted the exhibits and, the next day, allowed the State to late-endorse Maries County Bank bookkeeping project manager Robin Kleffner to authenticate the bank images; Rector objected to the late disclosure.
Kleffner testified about the bank's practice of retaining computer images and charging back the checks; the jury convicted Rector and this Court affirmed on direct appeal (Rector did not raise the late-endorsement issue then).
Rector filed a timely Rule 29.15 post-conviction motion claiming appellate counsel was ineffective for not raising the late-endorsement claim; the motion court (same judge as trial) denied relief on the stipulated record and affidavit.
This appeal challenges only whether appellate counsel was ineffective for failing to raise the late-endorsement issue; the court affirmed, finding no reasonable probability of a different outcome because the trial court did not abuse its discretion in permitting the late endorsement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether appellate counsel was ineffective for not raising the late-endorsement of the bank witness on direct appeal	Rector: counsel should have raised the late-endorsement claim because it rendered evidence inadmissible and prejudiced his appeal	State: counsel reasonably declined to raise it because the trial court acted within its broad discretion and Rector cannot show prejudice	Denied — no reasonable probability the direct appeal outcome would differ; appellate counsel not ineffective
Whether the trial court abused its discretion by permitting the late endorsement of the bank recordkeeper	Rector: late endorsement was improper, prejudicial, and should justify reversal	State: endorsement was in good faith to cure an authentication question; testimony was foreseeable, not surprising, and Rector sought no continuance	No abuse of discretion — Chaney factors favor admission; no prejudice shown

Strickland v. Washington, 466 U.S. 668 (establishes two-prong ineffective-assistance test)
State v. Chaney, 967 S.W.2d 47 (sets factors for review of late witness endorsements)
State v. Zuroweste, 570 S.W.3d 51 (failure to request continuance may indicate lack of prejudice from late endorsement)
Tate v. State, 461 S.W.3d 15 (explains prejudice prong for appellate counsel claims)
Mallow v. State, 439 S.W.3d 764 (standard of review for denial of post‑conviction relief)
State v. Taylor, 134 S.W.3d 21 (defines abuse of discretion standard)