Christina Halter Missouri Cases

Christina Halter appealed the motion court's judgment denying her amended Rule 29.15 motion for post-conviction relief without an evidentiary hearing. She contended the motion court failed to conduct an independent inquiry into whether she was abandoned by counsel, given the untimely filing of her amended motion. The appellate court reversed the motion court's judgment and remanded the case, holding that the motion court clearly erred by not making a record of an independent inquiry into abandonment, which is mandatory when an untimely amended motion raises a presumption of abandonment.

Christina Halter appealed her conviction for financial exploitation of a disabled person and Medicaid fraud, challenging instructional errors, unauthorized civil penalties, and her sentence. The appellate court affirmed the judgment in all respects except for the sentencing on two counts of financial exploitation. The court reversed the portion of the sentence that imposed both imprisonment and restitution, finding it to be an unauthorized disposition under then-applicable Missouri law, and remanded for resentencing on those counts.