assistance because trial counsel failed to object when the prosecutor referred to him as a liar during closing argument. To prove ineffectiveness for failing to object, Mr. Mitchem had to show that an objection would have been meritorious and the failure to object substantially deprived him of a fair trial. Jackson v. State, 205 S.W.3d 282, 288 (Mo.App. E.D. 2006). Trial counsel cannot be ineffective for failing to make a nonmeritorious objee tion. Id. On direct appeal, this court found there was no error, plain or otherwise, in allowing the prosecutor to refer to Mr. Mitchem as a liar and characterize his testimony as a lie, because the comments were reasonable inferences from the evidence. Because of this finding, Mr. Mit-chem’s second point is denied. See Ringo, 120 S.W.3d at 746 (<HOLDING>). Ineffectiveness of Appellate Counsel In the
holding that affidavit of appellate counsel summarizing conversations with trial counsel in which trial counsel admitted making errors is hearsay and cannot establish ineffective assistance claim holding that errors not raised before the trial court will not generally be considered on appeal holding counsel cannot be ineffective based on errors that the appellate court determined on direct appeal were not errors plain or otherwise holding that it is an abuse of discretion to make errors of law or clear errors of factual determination holding that instructional errors that are trial errors are subject to harmless error analysis