Missouri Court of Appeals, Western District / Mar 31, 2020
Jason L. Berry vs. State of Missouri
Jason Berry appealed the denial of his Rule 29.15 motion for post-conviction relief, arguing he received ineffective assistance of counsel because he was dissatisfied with his assigned public defender and was unable to have a different one assigned. The motion court denied his request, finding no irreconcilable conflict or complete breakdown in communication. The appellate court affirmed, holding that Berry failed to demonstrate justifiable dissatisfaction with counsel, as mere personality conflicts or disagreements on trial strategy are insufficient to warrant substitution of counsel.