Sanders v. State

On February 16, 2017, this Court issued an opinion in this cause and transferred it, pursuant to Rule 83.02,1 to the Supreme Court of Missouri. The issue that was pending in the Supreme Court of Missouri at the time of our opinion was whether an “order of notification” was an appointment of counsel. On November 2, 2017, the Supreme Court entered an order re-transferring the cause to this Court in light of two opinions entered on April 25, 2017, Creighton v. State, 520 S.W.3d 416 (Mo. banc 2017), and Hopkins v. State, 519 S.W.3d 433 (Mo. banc 2017).

In Creighton and Hopkins, the Supreme Court…