Missouri Court of Appeals, Western District / Apr 4, 2023
State of Missouri vs. David A. Harris
David A. Harris appealed his convictions for second-degree murder, first-degree assault, and armed criminal action, following a jury trial. He claimed the trial court plainly erred by not inquiring into his trial counsel's conflict of interest and that there was insufficient evidence to support his convictions. The appellate court affirmed the judgment, holding that conflict of interest claims are not cognizable on direct appeal but are proper for Rule 29.15 motions, and that sufficient evidence supported the jury's verdict.