Missouri Court of Appeals, Eastern District / Sep 26, 2023
Jihad A. Spann, Appellant, vs. State of Missouri, Respondent.
Jihad A. Spann appealed the denial of his Rule 29.15 motion for post-conviction relief after an evidentiary hearing. Spann argued the motion court erred by not conducting an independent inquiry into his post-conviction counsel's alleged abandonment and by failing to issue findings of fact and conclusions of law on all claims in his pro se motion. The Eastern District affirmed, holding that counsel's timely filing of an amended motion precluded an abandonment claim, and the amended motion superseded the pro se motion, requiring findings only on the amended claims.