State ex rel. Zahnd v. Van Amburg, 533 S.W.3d 227

Nelson and Walker pleaded guilty to felony stealing (§ 570.030.3(1)) and were sentenced (both sentences suspended and probation imposed).
After this Court decided Bazell (holding stealing could not be enhanced to a felony), Nelson and Walker — while still on probation — moved in circuit court under Rule 29.12(b) to amend their convictions to class A misdemeanors and reduce sentences.
The circuit court sustained the Rule 29.12(b) motions and amended the judgments to misdemeanors, reducing their jail terms.
The Platte County prosecuting attorney sought writs of prohibition; this Court issued preliminary writs directing the circuit court to vacate its orders.
The central legal question was whether the circuit court retained jurisdiction after sentence to adjudicate Rule 29.12(b) motions and amend final judgments.

Issue	Plaintiff's Argument (Prosecutor)	Defendant's Argument (Nelson/Walker)	Held
Whether the circuit court had jurisdiction post‑sentence to adjudicate Rule 29.12(b) motions and amend convictions	Court exhausted jurisdiction at sentencing; post‑sentence action under Rule 29.12(b) was void; prohibition proper	Rule 29.12(b) motions could be considered and judgments amended because the original judgments were not final or were void due to being contrary to law	The court lacked jurisdiction after sentence; Rule 29.12(b) does not create a post‑sentence remedy; orders sustaining the motions and amended judgments were void — writs made permanent
Whether State v. Morris (holding a sentence contrary to law is not a final judgment) remains good law	(implicit) finality doctrine governs; Morris should be overruled if inconsistent	Morris argued a sentence contrary to law is void and thus not final, allowing correction after sentencing	Morris overruled to the extent it held a sentence contrary to law is not a final judgment; an erroneous but unauthorized sentence is not void; finality occurs at sentencing

State v. Bazell, 497 S.W.3d 263 (Mo. banc 2016) (construing § 570.030 and holding certain stealing enhancements invalid)
State v. Larson, 79 S.W.3d 891 (Mo. banc 2002) (a criminal judgment becomes final when sentence is imposed)
State ex rel. Simmons v. White, 866 S.W.2d 443 (Mo. banc 1993) (once sentence is imposed the trial court exhausts its jurisdiction and post‑sentence actions are void unless authorized)
Spicer v. Donald N. Spicer Revocable Living Trust, 336 S.W.3d 466 (Mo. banc 2011) (after a judgment is final, trial court is divested of jurisdiction; further actions are void)
J.C.W. ex rel. Webb v. Wydskalla, 275 S.W.3d 249 (Mo. banc 2009) (clarifying distinction between authority and constitutionally recognized jurisdiction)
Stevens v. State, 208 S.W.3d 893 (Mo. banc 2006) (reaffirming that a judgment is final when sentence is entered)
State v. Morris, 719 S.W.2d 761 (Mo. banc 1986) (overruled insofar as it held a sentence contrary to law cannot constitute a final judgment)