Missouri Court of Appeals, Eastern District / Jun 7, 2022
Layette C. Williams, Appellant, vs. State of Missouri, Respondent.
Layette Williams appealed the denial of his Rule 29.15 motion for post-conviction relief without an evidentiary hearing. Williams argued his trial counsel was ineffective for not objecting to a probation condition requiring him to pay child support from his Supplemental Security Income (SSI) benefits, which he claimed federal law prohibits from attachment. The Eastern District of the Missouri Court of Appeals affirmed, holding that a claim challenging a condition of probation is not cognizable in a Rule 29.15 proceeding because probation is neither a conviction nor a sentence.