Missouri Court of Appeals, Western District / Mar 21, 2023
Lakeith R. Courtney vs. State of Missouri
Lakeith R. Courtney appealed the denial of his Rule 24.035 motion for post-conviction relief. Courtney argued that the sentencing court denied him due process and meaningful allocution by refusing to consider evidence related to self-defense as mitigation during his sentencing after he pleaded guilty to murder and armed criminal action. The appellate court affirmed the motion court's denial, finding no clear error. It held that a guilty plea waives self-defense as an absolute defense, and the sentencing court's ruling did not prohibit Courtney from presenting mitigating evidence, but merely clarified that self-defense would not be considered as a defense.