Missouri Court of Appeals, Western District / May 28, 2019
Leo A. Cranford vs. State of Missouri
Leo Cranford appealed the denial of his Rule 24.035 motion for post-conviction relief, arguing his plea counsel provided ineffective assistance by failing to advise him about the parole eligibility consequences of his guilty pleas for first-degree child molestation and first-degree statutory sodomy. The motion court denied the motion, concluding that parole eligibility is a collateral consequence about which counsel has no duty to inform. The appellate court affirmed, holding that the distinction between direct and collateral consequences remains valid in Missouri, and counsel's failure to advise on parole eligibility does not constitute ineffective assistance of counsel.