Missouri Court of Appeals, Eastern District / Jun 8, 2021
State of Missouri, Respondent, v. Cruz Howell, Appellant.
Cruz Howell appealed his convictions for three counts of second-degree domestic assault, arguing the trial court erred by denying his request for counsel after trial began and by denying his motions to dismiss for speedy-trial violations. The appellate court affirmed the trial court's judgment. It held that the trial court did not plainly err in denying Howell's last-minute request for counsel, as it would have required a continuance despite his prior valid waiver. The court also found no plain error in denying the speedy-trial motions, concluding Howell failed to prove actual prejudice from the delay.