Luleff inquiry (Missouri) · Go Syfert
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Luleff inquiry in Missouri

5 Missouri opinions name it 1 courts 1994–2019 0 in the last five years

The cases below were cited by Missouri courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
Cameron v. Stategreen
moctapp · 1993 · cited in 2 Missouri opinions naming this issue, 1994–1994
2 sentences

1994Bonar rests his appeal on Cameron v. State, 863 S.W.2d 385 (Mo.App.1993), in which this court’s Southern District remanded a Rule 24.035 action for a Luleff inquiry.

1994Bonar rests his appeal on Cameron v. State, 863 S.W.2d 385 (Mo.App.1993), in which this court’s Southern District remanded a Rule 24.035 action for a Luleff inquiry.

22
Luleff v. Stategreen
mo · 1991 · cited in 2 Missouri opinions naming this issue, 1994–1994
2 sentences

1994Because the record indicates that appointed counsel made the determinations required by Rule 29.15(e), the Luleff presumption, 807 S.W.2d at 498 [3], did not arise, and sua sponte inquiry by the motion court was not required.

1994Because the record indicates that appointed counsel made the determinations required by Rule 29.15(e), the Luleff presumption, 807 S.W.2d at 498 [3], did not arise, and sua sponte inquiry by the motion court was not required.

12
State v. Wetzelgreen
moctapp · 1991 · cited in 1 Missouri opinions naming this issue, 2018–2018
2 sentences

2018A Luleff inquiry may be required, however, "[e]ven though the record may reflect some activity by appointed counsel to demonstrate compliance with Rule 29.15(e)." Poe v. State , 820 S.W.2d 325 , 327 (Mo. App. W.D. 1991) (emphasis added).

2018A Luleff inquiry may be required, however, "[e]ven though the record may reflect some activity by appointed counsel to demonstrate compliance with Rule 29.15(e)." Poe v. State , 820 S.W.2d 325 , 327 (Mo. App. W.D. 1991) (emphasis added).

11
Brown v. Stategreen
moctapp · 1998 · cited in 1 Missouri opinions naming this issue, 2018–2018
1 sentence

2018Id. at 292 ; accord , Brown v. State , 968 S.W.2d 725 , 727 (Mo. App. E.D. 1998) (reversing for Luleff inquiry where counsel's statement in lieu of an amended motion indicated that counsel had not communicated with the movant as part of counsel's determination that an amended motion was unnecessary).

11
State v. Tolergreen
moctapp · 1994 · cited in 1 Missouri opinions naming this issue, 1995–1995
2 sentences

1995Id. at 163.

1995Id. at 163.

11
Kinder v. Stategreen
moctapp · 1993 · cited in 1 Missouri opinions naming this issue, 1994–1994
1 sentence

1994See, e.g., State v. Dewey, 869 S.W.2d 834, 838 (Mo.App.1994); Kinder v. State, 867 S.W.2d 667, 670 (Mo.App.1993); State v. Shields, 862 S.W.2d 503, 506 (Mo.App.1993).

11
Bonar v. Stategreen
moctapp · 1994 · cited in 1 Missouri opinions naming this issue, 1994–1994
2 sentences

1994Unlike the “notice” in Cameron , the affidavit here affirmatively recites the action by appointed counsel designed to ascertain all grounds for relief known to Toler, i.e., counsel “inquired of movant regarding any additional claims and facts known to him.” See Bonar v. State, 880 S.W.2d 384, 386 [3] (Mo.App.1994).

1994Bonar, 880 S.W.2d at 386 [5].

11
State v. Deweygreen
moctapp · 1994 · cited in 1 Missouri opinions naming this issue, 1994–1994
1 sentence

1994See, e.g., State v. Dewey, 869 S.W.2d 834, 838 (Mo.App.1994); Kinder v. State, 867 S.W.2d 667, 670 (Mo.App.1993); State v. Shields, 862 S.W.2d 503, 506 (Mo.App.1993).

11
State v. Shieldsgreen
moctapp · 1993 · cited in 1 Missouri opinions naming this issue, 1994–1994
1 sentence

1994See, e.g., State v. Dewey, 869 S.W.2d 834, 838 (Mo.App.1994); Kinder v. State, 867 S.W.2d 667, 670 (Mo.App.1993); State v. Shields, 862 S.W.2d 503, 506 (Mo.App.1993).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Missouri. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
McDaris v. State green
mo · 1992
2 sentences

2019Alok Ahuja, Judge 1 The Supreme Court explained in McDaris v. State, 843 S.W.2d 369 (Mo. banc 1992), that the Luleff inquiry “may be as formal or informal as the motion court deems necessary to resolve the question of abandonment by counsel, including, but not limited to, a written response and opportunity to reply, a telephone conference call, or a hearing,” so long as the inquiry results in “a sufficient record . . . to demonstrate on appeal that the motion court’s determination of the abandonment issue is not clearly erroneous.” Id. at 371 n.1. 2

2019Alok Ahuja, Judge 1 The Supreme Court explained in McDaris v. State, 843 S.W.2d 369 (Mo. banc 1992), that the Luleff inquiry “may be as formal or informal as the motion court deems necessary to resolve the question of abandonment by counsel, including, but not limited to, a written response and opportunity to reply, a telephone conference call, or a hearing,” so long as the inquiry results in “a sufficient record . . . to demonstrate on appeal that the motion court’s determination of the abandonment issue is not clearly erroneous.” Id. at 371 n.1. 2

22018–2019
Tabor v. State green
moctapp · 2009
1 sentence

2018Tabor v. State , 282 S.W.3d 381 , 385 (Mo. App. S.D. 2009) ( Luleff inquiry required even though counsel filed an entry of appearance, requested additional time to file a brief, and "forward[ed] ... correspondence to the motion court relating to the 'status of the case' on three occasions"); Gehlert v. State , 276 S.W.3d 889 , 892-93 (Mo. App. W.D. 2009) (remanding for abandonment inquiry where appointed counsel entered his appearance, requested guilty plea and sentencing transcripts, and communicated with movant, his daughter, and the court concerning status of case); Poe , 820 S.W.2d at 327

12018–2018
State v. Taylor green
moctapp · 1992
2 sentences

2018Similarly, in Trehan v. State , 835 S.W.2d 427 (Mo. App. S.D. 1992), the Southern District held that a Luleff inquiry was required where, "[d]espite the flagrant inadequacy of the movant's pro se motion, his appointed counsel simply incorporated the pro se motion, with its blank paragraph 9, into the amended motion and added two additional grounds for relief which the movant now correctly describes as 'uncognizable.' " Id. at 429 .

2018Similarly, in Trehan v. State , 835 S.W.2d 427 (Mo. App. S.D. 1992), the Southern District held that a Luleff inquiry was required where, "[d]espite the flagrant inadequacy of the movant's pro se motion, his appointed counsel simply incorporated the pro se motion, with its blank paragraph 9, into the amended motion and added two additional grounds for relief which the movant now correctly describes as 'uncognizable.' " Id. at 429 .

12018–2018
Pope v. State green
moctapp · 2002
2 sentences

2018Instead, the Court has explained that "[a]n amended motion ... has been deemed a nullity"-thus triggering the obligation to perform a Luleff inquiry-"when counsel merely replicated a facially deficient pro se motion." Stanley , 420 S.W.3d at 542 (citing Pope v. State , 87 S.W.3d 425 , 427-29 (Mo. App. W.D. 2002) ).

2018Instead, the Court has explained that "[a]n amended motion ... has been deemed a nullity"-thus triggering the obligation to perform a Luleff inquiry-"when counsel merely replicated a facially deficient pro se motion." Stanley , 420 S.W.3d at 542 (citing Pope v. State , 87 S.W.3d 425 , 427-29 (Mo. App. W.D. 2002) ).

12018–2018
Moore v. State green
mo · 1996
1 sentence

2018Id. at 292 ; accord , Brown v. State , 968 S.W.2d 725 , 727 (Mo. App. E.D. 1998) (reversing for Luleff inquiry where counsel's statement in lieu of an amended motion indicated that counsel had not communicated with the movant as part of counsel's determination that an amended motion was unnecessary).

12018–2018
Gehlert v. State neutral
moctapp · 2009
1 sentence

2018Tabor v. State , 282 S.W.3d 381 , 385 (Mo. App. S.D. 2009) ( Luleff inquiry required even though counsel filed an entry of appearance, requested additional time to file a brief, and "forward[ed] ... correspondence to the motion court relating to the 'status of the case' on three occasions"); Gehlert v. State , 276 S.W.3d 889 , 892-93 (Mo. App. W.D. 2009) (remanding for abandonment inquiry where appointed counsel entered his appearance, requested guilty plea and sentencing transcripts, and communicated with movant, his daughter, and the court concerning status of case); Poe , 820 S.W.2d at 327

12018–2018
Travis M. Stanley v. State of Missouri green
mo · 2014
2 sentences

2018Instead, the Court has explained that "[a]n amended motion ... has been deemed a nullity"-thus triggering the obligation to perform a Luleff inquiry-"when counsel merely replicated a facially deficient pro se motion." Stanley , 420 S.W.3d at 542 (citing Pope v. State , 87 S.W.3d 425 , 427-29 (Mo. App. W.D. 2002) ).

2018Instead, the Court has explained that "[a]n amended motion ... has been deemed a nullity"-thus triggering the obligation to perform a Luleff inquiry-"when counsel merely replicated a facially deficient pro se motion." Stanley , 420 S.W.3d at 542 (citing Pope v. State , 87 S.W.3d 425 , 427-29 (Mo. App. W.D. 2002) ).

12018–2018

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