CONNIE SANDERS-FORD v. STATE OF MISSOURI

CourtMissouri Court of Appeals
DecidedApril 8, 2020
DocketSD36169
StatusPublished

This text of CONNIE SANDERS-FORD v. STATE OF MISSOURI (CONNIE SANDERS-FORD v. STATE OF MISSOURI) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CONNIE SANDERS-FORD v. STATE OF MISSOURI, (Mo. Ct. App. 2020).

Opinion

Missouri Court of Appeals Southern District Division One

CONNIE SANDERS-FORD, ) ) Appellant, ) ) No. SD36169 ) STATE OF MISSOURI, ) FILED: April 8, 2020 ) Respondent. )

APPEAL FROM THE CIRCUIT COURT OF McDONALD COUNTY

Honorable Timothy W. Perigo, Judge

AFFIRMED

Connie Sanders-Ford (“Movant”) was found guilty by a jury of first-degree murder and

armed criminal action for which she was sentenced, respectively and concurrently, to life in

prison without parole and three-years in prison. 1 Movant timely filed both a pro se and an

amended Rule 29.15 motion for post-conviction relief. 2 In the latter, Movant claimed, among

others, that she received ineffective assistance of counsel (“IAC”) in rejecting the State’s pre-

trial plea offer for a 25-year sentence for second-degree murder (the “plea offer”) and, instead,

proceeding to trial. Following an evidentiary hearing on her amended motion, the motion court

1 Movant’s convictions were affirmed by this court in State v. Sanders-Ford, 527 S.W.3d 223 (Mo.App. 2017). 2 All rule references are to Missouri Court Rules (2019).

1 entered its judgment denying Movant’s IAC claim related to the plea offer. Movant timely

appeals that denial.

The motion court found and concluded as follows:

In this point [M]ovant claims that … her trial counsel was ineffective for telling her that she would have to serve 85% of her sentence if she accepted the state’s offer of 25 years in prison on the reduced charge of murder in the second degree. Movant’s trial counsel’s advice would have been accurate if [M]ovant was younger, but Section 558.019(3) RSMo makes an exception for older defendants.[ 3] Instead of being required to serve 85% of her sentence movant would have been eligible for parole after serving just 40% of her sentence because she would have been older than 70 years of age by then. At the hearing on this motion, trial counsel admitted that he was unaware of this exception and was therefore inaccurate in his advice to [M]ovant on this matter. However, during the hearing on this motion the prosecutor in charge of the trial and plea bargain offer stated that he was also unaware of the exception for older defendants found in section 558.019(3). The prosecutor state [sic] that the plea offer was made with the intent of both he and the victim’s family that [M]ovant never be released from prison. The prosecutor also said that had the mistake been realized before [M]ovant entered her plea to the lesser charge that the offer would have been withdrawn. Movant has failed to prove that she was prejudiced by trial counsel’s inaccurate advice because it is speculation that the prosecutor would not have discovered his mistake before [M]ovant had an opportunity to enter her plea. At a sentencing hearing on the proposed plea offer, most likely either the prosecutor or the victim would have stated that [Movant] would have to serve 85% of the sentence (assuming prosecutor had not yet discovered RSMo 558.019(3).

At this point, the Court being presumed to know the law would have corrected the prosecutor.[ 4] Court believes the prosecutor’s statement that he would have withdrawn the plea of guilty discovery [sic] of RSMo 558.019(3).

Applicable Legal Principles

This Court’s review of the denial of a Rule 29.15 motion for post-conviction relief is

limited to determining whether the motion court’s findings of fact and conclusions of law are

3 Section 558.019.3 RSMo (2016) provides: Other provisions of the law to the contrary notwithstanding, any offender who has pleaded guilty to or has been found guilty of a dangerous felony as defined in section 556.061 and is committed to the department of corrections shall be required to serve a minimum prison term of eighty-five percent of the sentence imposed by the court or until the offender attains seventy years of age, and has served at least forty percent of the sentence imposed, whichever occurs first. (Emphasis added.) 4 The motion court judge was also the trial court judge in the underlying criminal case.

2 clearly erroneous. Rule 29.15(k); Williams v. State, 168 S.W.3d 433, 439 (Mo. banc 2005).

Such “[f]indings and conclusions are clearly erroneous only if a full review of the record

definitely and firmly reveals that a mistake was made.” Morrow v. State, 21 S.W.3d 819, 822

(Mo. banc 2000). It is incumbent upon the movant in a post-conviction motion to prove his or

her claims for relief by a preponderance of the evidence, Rule 29.15(i), and this Court presumes

that the motion court’s findings and conclusions are correct, Wilson v. State, 813 S.W.2d 833,

835 (Mo. banc 1991). “The trial court has the ‘superior opportunity to determine the credibility

of witnesses,’ and this Court defers to the trial court’s factual findings and credibility

determinations.” Zink v. State, 278 S.W.3d 170, 178 (Mo. banc 2009) (quoting State v. Rousan,

961 S.W.2d 831, 845 (Mo. banc 1998)).

In order to prove a claim that counsel’s assistance was ineffective, the movant must

demonstrate (1) that counsel’s representation failed to conform to the degree of skill, care, and

diligence of a reasonably competent attorney rendering similar services under similar

circumstances (performance prong); and (2) that the movant was prejudiced as a result of

counsel’s failure (prejudice prong). Strickland v. Washington, 466 U.S. 668, 687 (1984);

Sanders v. State, 738 S.W.2d 856, 857 (Mo. banc 1987). In reviewing such claims, we are not

required to examine both prongs; if a movant fails to satisfy the performance prong, we need not

consider the prejudice prong, and vice versa. Sanders, 738 S.W.2d at 857.

To show prejudice from ineffective assistance of counsel where a plea offer has lapsed or been rejected because of counsel’s deficient performance, defendants must demonstrate a reasonable probability they would have accepted the earlier plea offer had they been afforded effective assistance of counsel. Defendants must also demonstrate a reasonable probability the plea would have been entered without the prosecution canceling it or the trial court refusing to accept it, if they had the authority to exercise that discretion under state law. To establish prejudice in this instance, it is necessary to show a reasonable probability that the end result of the criminal process would have been more favorable by reason of a plea to a lesser charge or a sentence of less prison time.

3 Missouri v. Frye, 566 U.S. 134, 147 (2012). “[A]s a general rule, Missouri law permits the State

discretion to withdraw a plea offer, even an accepted plea offer, at any time prior to the offer’s

acceptance by the trial court.” Frye v. State, 392 S.W.3d 501, 506 (Mo.App. 2013). Similarly,

subject only to constraints or limitations imposed by Rule 24.02(d), a Missouri trial court has

discretion to accept or reject a plea agreement based on the State’s plea offer. Id. at 507.

In Missouri, therefore, in order to prove the Strickland prejudice prong where a plea offer

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Missouri v. Frye
132 S. Ct. 1399 (Supreme Court, 2012)
Zink v. State
278 S.W.3d 170 (Supreme Court of Missouri, 2009)
Wilson v. State
813 S.W.2d 833 (Supreme Court of Missouri, 1991)
Sanders v. State
738 S.W.2d 856 (Supreme Court of Missouri, 1987)
State v. Rousan
961 S.W.2d 831 (Supreme Court of Missouri, 1998)
Morrow v. State
21 S.W.3d 819 (Supreme Court of Missouri, 2000)
Williams v. State
168 S.W.3d 433 (Supreme Court of Missouri, 2005)
Frye v. State
392 S.W.3d 501 (Missouri Court of Appeals, 2013)
State v. Sanders-Ford
527 S.W.3d 223 (Missouri Court of Appeals, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
CONNIE SANDERS-FORD v. STATE OF MISSOURI, Counsel Stack Legal Research, https://law.counselstack.com/opinion/connie-sanders-ford-v-state-of-missouri-moctapp-2020.