Missouri Court of Appeals, Eastern District / Nov 21, 2023
Sokol Zuko, Appellant, vs. State of Missouri, Respondent.
Sokol Zuko appealed the denial of his Rule 24.035 postconviction motion, arguing that his counsel had a conflict of interest by representing him in both his direct appeal and the postconviction proceeding. Zuko contended that the circuit court erred by not inquiring into this conflict, which he claimed constituted structural error. The appellate court affirmed the circuit court's judgment, holding that claims regarding the competence or diligence of postconviction counsel are categorically unreviewable because there is no constitutional right to counsel in postconviction proceedings.