Walking out on the Check: How Missouri Abandoned Its Public Defenders and Left the Poor to Foot the Bill

This Note looks at the Pratte decision, which arose primarily from the MSPD\u27s most recent effort to cope with its drastically insufficient level of funding. In Missouri, as in many other states, the funding crisis has manifested itself in the form of extremely high caseloads for public defender offices. Straining to prevent a system-wide collapse, the Missouri Public Defender Commission (Commission) enacted regulations that gave each district office of the public defender the power to manage its caseload. These regulations effectively gave each district office the discretion to deny representation to indigent defendants who were otherwise entitled to counsel under Missouri law. When circuit court judges began rejecting public defenders\u27 attempts to employ the regulations, several different public defenders and the Commission sued to enjoin enforcement of the trial courts\u27 orders