{"disclaimer":"This is a summary of public court records and is not legal advice. Missouri slip opinions may be modified or withdrawn; consult the official source.","party":{"slug":"angela-l-brown","displayName":"Angela L. Brown","totalCases":1},"cases":[{"caseId":"moappd:ed108001:2020-03-10","opinionId":"893d2e10-0acd-5537-b22b-e5fc03e862a3","slug":"angela-l-brown-appellant-v-state-of-missouri-respondent-108001","caseName":"Angela L. Brown, Appellant, v. State of Missouri, Respondent.","caseNumber":"ED108001","court":"moappd","courtLabel":"Missouri Court of Appeals, Eastern District","decisionDate":"2020-03-10","year":2020,"display_summary":"Angela Brown appealed the motion court's dismissal without prejudice of her Rule 24.035 post-conviction motion. Brown had pleaded guilty to stealing and received a suspended imposition of sentence (SIS), arguing her motion should have been held in abeyance as premature. The appellate court affirmed the dismissal, holding that a movant with an SIS lacks standing to file a Rule 24.035 motion because there is no conviction or sentence to challenge. The court clarified that such a motion is not \"premature\" in the sense that it should be held in abeyance, as the time for proper filing may never arise.","primaryTopic":"criminal-procedure","topicSlugs":["criminal-procedure","appellate-procedure","standard-of-review"],"outcomeNorm":"mixed","officialSourceUrl":"https://www.courts.mo.gov/file.jsp?id=151456","detailUrl":"https://ott.law/missouri-courts/opinions/angela-l-brown-appellant-v-state-of-missouri-respondent-108001","relatedPracticeAreas":[{"slug":"criminal-law","label":"Criminal Law","href":"/practice-areas/criminal-law","score":40,"source":"tag","evidence":["tag: criminal-law","topic: criminal-procedure","text: state of missouri","text: conviction","text: sentence"],"url":"https://ott.law/practice-areas/criminal-law"},{"slug":"litigation","label":"Civil Litigation","href":"/practice-areas/litigation","score":12,"source":"topic","evidence":["topic: appellate-procedure"],"url":"https://ott.law/practice-areas/litigation"}],"role":"appellant"}]}