Jamel Yates Missouri Cases

Jamel Yates appealed the denial of his Rule 29.15 motion for post-conviction relief, arguing his trial counsel was ineffective for failing to investigate and present evidence of juror misconduct. The alleged misconduct involved a juror reporting extrinsic information about the definition of an assault charge during deliberations. The Eastern District of the Missouri Court of Appeals affirmed the motion court's judgment, finding that Yates failed to demonstrate prejudice from the alleged misconduct because the extraneous information was not material to the jury's verdict on the counts of conviction.

Movant Jamel Yates appealed the denial of his Rule 29.15 motion for post-conviction relief without an evidentiary hearing. Yates claimed trial counsel was ineffective for failing to investigate juror misconduct and that the motion court abused its discretion by denying post-conviction counsel's requests to contact jurors. The appellate court reversed the motion court's judgment, finding it was an abuse of discretion to deny permission to contact jurors and clearly erroneous to deny the ineffective assistance of counsel claim without an evidentiary hearing. The case was remanded for an evidentiary hearing and to allow post-conviction counsel to contact the jurors.