CHRIS COURTOIS, Movant- Missouri Cases

Chris Courtois appealed the denial of his Rule 29.15 motion for post-conviction relief, raising two points. First, he argued his appellate counsel was ineffective for failing to challenge the trial court's denial of his motion to suppress statements to police. Second, he claimed the motion court plainly erred by not inquiring whether his amended motion included all known claims. The Southern District affirmed the motion court's judgment, concluding that appellate counsel made a strategic decision not to pursue a meritless claim regarding the voluntariness of Courtois's statements, and that plain error review is not available for claims not raised in a post-conviction motion.

Chris Courtois appealed the denial of his Rule 29.15 amended motion for post-conviction relief, which alleged ineffective assistance of appellate counsel. The appellate court determined that the motion court had granted an extension for filing the amended motion after the mandatory deadline had passed, rendering the motion untimely. Consequently, the court reversed the motion court's order and remanded the case with directions for the motion court to conduct an abandonment inquiry to determine if Movant was abandoned by post-conviction counsel before proceeding further.