Missouri Court of Appeals, Southern District / Nov 8, 2018
JAMES A. VALLEY, Movant-Appellant vs. STATE OF MISSOURI, Respondent-Respondent
James A. Valley appealed the denial of his Rule 24.035 motion for post-conviction relief. Valley had pled guilty to felony stealing and received a five-year sentence. He argued that a subsequent Supreme Court decision, State v. Bazell, reclassified his offense as a misdemeanor, making his sentence unlawful. The appellate court affirmed the motion court's judgment, holding that Bazell's prospective application rule meant it did not apply to post-conviction relief motions.