Missouri Court of Appeals, Eastern District / Feb 17, 2026
State of Missouri, Respondent, v. Elizabeth M. Speer, Appellant.
Elizabeth M. Speer appealed her convictions for second-degree property damage and fourth-degree assault, arguing the trial court failed to conduct an adequate Faretta hearing and did not obtain a written waiver of counsel. The State conceded error on both points. The appellate court reversed Speer's convictions and sentences, remanding the case for a new trial, holding that the trial court failed to ensure a knowing and intelligent waiver of counsel as required by the Sixth Amendment and Section 600.051.