Fields v. State
541 S.W.3d 45
| Mo. Ct. App. | 2018Background
- Fields was convicted (2010) of first-degree murder and armed criminal action; mandate issued December 20, 2012.
- Rule 29.15(b) required a post-conviction motion within 90 days of the mandate (deadline March 20, 2013).
- Fields alleges she prepared a pro se 29.15 motion and mailed it to her direct-appeal counsel for filing before the deadline because she had mail problems in administrative segregation.
- Counsel (quadriplegic) had surgery Feb 6, 2013 and allegedly became unexpectedly bedridden and unable to timely file Fields’ motion.
- Fields filed her Rule 29.15 motion on January 4, 2017; the circuit court dismissed it as untimely without an evidentiary hearing.
- The court of appeals reversed and remanded, concluding Fields sufficiently alleged "active third-party interference" to excuse the untimely filing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Fields' untimely Rule 29.15 motion can be excused by "active third-party interference" | Fields says she timely prepared and mailed the pro se motion to counsel who agreed to file it; counsel's unexpected post-op incapacitation prevented timely filing | State contends Fields’ delay after the deadline and lack of subsequent diligence defeat her claim | Reversed: allegations suffice to invoke the active-interference exception; dismissal without a hearing was incorrect |
| Whether post-deadline delay by Fields defeats an active-interference claim | Fields argues post-deadline actions are irrelevant because waiver occurred when counsel failed to file on time | State argues delay after the deadline shows lack of diligence and should bar relief | Held that post-deadline delay does not negate an active-interference claim; waiver occurs at the moment of the missed deadline, and later delay is not dispositive |
| Whether Fields pleaded sufficient facts to require an evidentiary hearing | Fields alleges she mailed motion before the deadline, counsel agreed to file, and counsel’s incapacitation prevented filing | State asserts Fields failed to allege she provided counsel sufficiently in advance or acted diligently after deadline | Court held allegations (timely mailing to counsel and counsel's incapacity) were sufficient to require further proceedings |
| Whether dismissal without prejudice was appealable | Not directly argued by parties; court noted dismissal without prejudice is typically non-final | State implied procedural finality; circuit court dismissed as untimely terminating Rule 29.15 relief | Court found the dismissal had practical effect of terminating Rule 29.15 relief and was appealable |
Key Cases Cited
- Price v. State, 422 S.W.3d 292 (Mo. banc 2014) (articulates "active interference" exception to Rule 29.15(b) deadlines)
- McFadden v. State, 256 S.W.3d 103 (Mo. banc 2008) (applies active-interference when counsel receives inmate's motion but fails to file it on time)
- Dorris v. State, 360 S.W.3d 260 (Mo. banc 2012) (movant must allege facts showing timeliness or an exception to time limits)
- Williams v. State, 415 S.W.3d 764 (Mo. App. W.D. 2013) (reversed dismissal where inmate alleged counsel's assurances and late filing by counsel)
- Propst v. State, 535 S.W.3d 733 (Mo. banc 2017) (standard of review for dismissal of postconviction relief motions)