Carruthers v. State

Summary

The Missouri appellate court affirmed the denial of the defendant’s pro se Rule 27.26 motion to vacate his robbery conviction and sentence. The court held that the plea-hearing record conclusively refuted his claim that narcotics rendered his guilty plea involuntary and that, under the law applicable when the motion was filed and decided, the trial court was not required to appoint counsel or hold an evidentiary hearing.

Holdings

1. No evidentiary hearing was required because the applicable version of Rule 27.26 permitted denial without a hearing when the factual allegations were refuted by facts elicited at the guilty-plea hearing, and Carruthers's plea-record statements directly refuted his later claim that he was incapable of making a knowing and voluntary decision.
2. The motion court did not err by failing to appoint counsel because, under the law applicable when the proceeding occurred, counsel was not required when no evidentiary hearing was necessary. Fields v. State, decided after the proceeding and expressly made prospective, did not apply retroactively.
3. No. A sentence imposed after a thorough hearing and presentence investigation, and within the statutory punishment range, could not be vacated through a Rule 27.26 motion merely because a participant in a separate proceeding received a lesser sentence.

Questions Presented

1. Whether the motion court was required to conduct an evidentiary hearing on Carruthers's Rule 27.26 claims.
2. Whether the motion court was required to appoint counsel for Carruthers in the pro se Rule 27.26 proceeding.
3. Whether Carruthers could obtain relief from his sentence based on the allegedly more lenient sentence imposed on a codefendant.

Disposition

affirmed