In a motion filed Friday in Jasper County Circuit Court, Springfield attorney Kristin Suzanne Jones pointed out that Montz is "a lifelong resident of the Joplin and Neosho area, is employed and has no prior felony convictions and only one minor misdemeanor conviction.
Jones asked that her motion be taken up as soon as possible, which will likely be his next court appearance 9 a.m. Wednesday.
The probable cause statement filed when the charge was still assault detailed the confrontation between Chris Montz, 24, Neosho and Reynolds at Highway 249 near the intersection with I-44.
The statement indicated Montz and Reynolds pulled to the shoulder and while the men were arguing, Reynolds punched Montz twice in the face. Montz pulled a gun and shot Reynolds in the head.
Charge in road rage shooting upgraded to murder in the first degree
Probable cause in road rage shooting: Reynolds punched Montz twice in the face; Montz pulled a gun and shot him in the head
Judge in 2015 court document: Neosho man accused in road rage death poses no threat to public safety