Missouri Court of Appeals, Western District / Jul 16, 2019
Umar Muhammad vs. State of Missouri
Umar Muhammad appealed the denial of his Rule 29.15 motion for post-conviction relief, which the motion court found untimely. Muhammad argued that his untimely filing should be excused due to his privately retained counsel's erroneous advice regarding the filing deadline, constituting third-party interference. The appellate court affirmed the motion court's judgment, holding that reliance on retained counsel's advice does not qualify as active third-party interference to excuse a mandatory filing deadline.