Fields v. State of Missouri, No.WD84506 (Mo. Ct. App. 2022)
Nature of Case: Appellant pled guilty, pursuant to a plea agreement, to two counts of first-degree statutory sodomy. Following his guilty plea, Appellant received two fourteen-year terms of imprisonment to be served consecutively. Appellant subsequently filed a timely motion to vacate, set aside, or correct the judgment in which he argued that his counsel failed to adequately inform him of the collateral consequences of his plea. Specifically, Appellant testified in an evidentiary hearing that his plea counsel never informed him that, following the completion of his sentence, his conviction could result in a lifetime civil commitment to the Missouri Department of Health as a “sexually violent predator” (“SVP”). Appellant stated that he would not have accepted the plea offer had he known about the possibility of future civil commitment.
The motion court denied Appellant’s motion. On appeal, Appellant solely argues that the motion court erred in denying his motion because he received ineffective counsel in that plea counsel failed to advise him of the possibility of involuntary commitment as an SVP.
Holding: The Court of Appeals affirmed the judgment of the motion court, concluding that unlike the risk of deportation assessed in Padilla v. Kentucky, 559 U.S. 356 (2010), civil commitment under Missouri’s SVP statute is a collateral consequence of a guilty plea as opposed to a presumptively mandatory consequence. For that reason, the Court declined to conclude that plea counsel was obligated to inform Appellant of this potential consequence. The Court also deferred to the motion court’s determination that Appellant’s testimony about the involuntary nature of his plea was not credible, and held that Appellant failed to establish the prejudice necessary to obtain postconviction relief for ineffective assistance of counsel.