Sanders v. State

We consider whether Hoeber v. State , 488 S.W.3d 648 (Mo. banc 2016), compels postconviction motion courts to categorically deem unreasonable such strategic concerns as trial counsel (Counsel) voiced here. Finding otherwise, we reverse a grant of postconviction relief and remand for further proceedings.

Background1

Colby Sanders (Movant) is serving five concurrent prison terms, effectively 40 *382years, from a jury trial for sex crimes against his child and stepchildren:

• 15 years for molesting stepdaughter B.S. (Count 1).

• 40 years for sodomizing B.S. (Count 3).

• 15 years for molesting second…