Missouri Court of Appeals, Western District / Sep 7, 2021
Scott W. Eckert vs. State of Missouri
Scott W. Eckert appealed the denial of his Rule 29.15 motion for post-conviction relief, arguing his trial counsel was ineffective for failing to dismiss victim tampering charges under the Uniform Mandatory Disposition of Detainers Law (UMDDL). Eckert contended his trial occurred beyond the 180-day UMDDL limit, even with conceded delays. The appellate court affirmed the motion court's judgment, finding that additional delays caused by Eckert's motion to dismiss and agreement to briefing tolled the UMDDL period, placing his trial within the statutory timeframe. The court also noted that Eckert failed to allege a constitutional speedy trial violation, which is a prerequisite for dismissal under UMDDL.