Missouri Court of Appeals, Western District / Sep 28, 2021
Alan L. Echols vs. State of Missouri
Alan Echols appealed the denial of his motion for post-conviction relief, which alleged a conflict of interest and abandonment by his retained counsel. Echols had been convicted of murder and armed criminal action in 1991, and his prior post-conviction motion was dismissed under the "escape rule." The appellate court affirmed the motion court's denial, holding that the "law of the case" doctrine barred relitigation of the conflict of interest claim, which had been previously deemed moot. Additionally, the court reiterated that the abandonment doctrine applies only to appointed counsel, not retained counsel.