Missouri Court of Appeals, Eastern District / Feb 21, 2023
Antoine Watkins, Appellant, v. State of Missouri, Respondent.
Antoine Watkins appealed the denial of his Rule 24.035 motion for post-conviction relief, arguing the sentencing court lacked authority to revoke his probation because his probationary period, adjusted for earned compliance credits, had expired. The motion court denied relief, citing a statutory bar on challenging earned compliance credits in post-conviction proceedings. The Eastern District affirmed the motion court's judgment, holding that the suspension of probation tolled the probationary period and suspended earned compliance credits, meaning the five-year period had not expired at the time of revocation.