Waggoner v. State

The majority holds that the circuit court was not required to conduct a sua sponte inquiry into the performance of Waggoner's appointed counsel. According to the majority, no independent inquiry was required because counsel showed some "signs of life" by filing an "amended" post-conviction relief motion which reproduced Waggoner's pro se motion with inconsequential changes. The majority apparently concludes that, so long as appointed counsel files something which purports to be an "amended" motion, counsel has discharged his or her performance obligations under Supreme Court Rule 29.15(e),…