Missouri Court of Appeals, Eastern District / Dec 2, 2025
Barry E. Anderson, Appellant, v. State of Missouri, Respondent.
Barry E. Anderson appealed the denial of his Rule 29.15 motion for post-conviction relief, arguing ineffective assistance of counsel. The motion court had found abandonment by counsel and reviewed his untimely amended motion. The appellate court affirmed the denial, holding that the amended motion was untimely because the abandonment doctrine does not apply to unappointed counsel, and the motion court's post hoc appointment was invalid. However, the court affirmed the judgment because all claims in Anderson's timely pro se motion had been properly adjudicated.