571 S.W.3d 207
Mo. Ct. App.2019Background
- Meadors was arrested on multiple forgery/stealing charges (St. Louis, St. Charles, Jefferson counties); he was in DOC custody on St. Louis and St. Charles matters and Jefferson County did not issue a detainer.
- Jefferson County filed a complaint Nov. 11, 2012 and issued a warrant Dec. 5, 2012; State executed the warrant and transported Meadors by writ in March 2015.
- The Jefferson County information was filed Jan. 25, 2016 (amended Jan. 27, 2016); Meadors pleaded guilty to forgery on Apr. 20, 2016 (84 days after the information).
- At the plea colloquy Meadors admitted the forgery, acknowledged prior convictions, understood the 7–15 year range, and expressly waived his right to a speedy trial; court found plea knowing and voluntary.
- Meadors was sentenced as a prior and persistent offender to eight years (per State recommendation).
- Meadors filed a Rule 24.035 post-conviction motion claiming plea counsel was ineffective for failing to move to dismiss for lack of a speedy trial; motion court denied relief without an evidentiary hearing and this appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plea counsel was ineffective for not moving to dismiss for speedy-trial violation | Meadors: counsel should have moved to dismiss; had counsel done so the charge would have been dismissed and he would not have pleaded guilty | State: Meadors waived speedy-trial claim by pleading guilty; delay measured from filing of information; any speedy-trial motion would have been meritless; Meadors failed to plead prejudice | Court affirmed: plea waived most ineffective-assistance claims; record refutes involuntariness and shows no meritorious speedy-trial claim; no prejudice pleaded |
| Whether Meadors’s guilty plea was involuntary or unknowing due to counsel’s failure re speedy trial | Meadors: plea was unknowing/involuntary because counsel did not pursue speedy-trial relief | State: colloquy shows Meadors expressly waived speedy-trial right and confirmed understanding; no claim counsel misinformed him | Court: record conclusively refutes involuntariness; colloquy establishes knowing waiver |
| Whether a UMDDL demand was triggered by Meadors’ July 2013 letter | Meadors: letter sought disposition and thus invoked UMDDL protections | State: letter did not satisfy UMDDL (not sent to prosecutor), was premature because no information filed and no detainer/functional equivalent existed | Court: UMDDL claim fails — procedural requirements not met and letter premature |
| Whether an evidentiary hearing was required on the Rule 24.035 motion | Meadors: alleged facts warrant hearing | State: files and record conclusively show no relief; Meadors did not plead required prejudice or a meritorious motion | Court: no evidentiary hearing required; motion court not clearly erroneous |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (ineffective assistance standard for performance and prejudice)
- Whitehead v. State, 481 S.W.3d 116 (Mo. App. E.D. 2016) (post-plea movant must show plea was unknowing/involuntary; record can refute need for hearing)
- Lane v. State, 317 S.W.3d 125 (Mo. App. 2010) (guilty plea waives ineffective-assistance claims except those affecting voluntariness/knowledge)
- State v. Sisco, 458 S.W.3d 304 (Mo. banc 2015) (delay for speedy-trial purposes measured from indictment/information or arrest)
- State v. Williams, 120 S.W.3d 294 (Mo. App. W.D. 2003) (defendant incarcerated on other charges not "accused" on separate pending charge until information filed)