People v. Ashford

2026 IL App (1st) 241387-U
CourtAppellate Court of Illinois
DecidedJanuary 22, 2026
Docket1-24-1387
StatusUnpublished

This text of 2026 IL App (1st) 241387-U (People v. Ashford) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Ashford, 2026 IL App (1st) 241387-U (Ill. Ct. App. 2026).

Opinion

2026 IL App (1st) 241387-U

FOURTH DIVISION Order filed: January 22, 2026

No. 1-24-1387

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

FIRST DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Respondent-Appellee, ) Cook County. ) v. ) No. 97 C 44081401 ) CORIS ASHFORD, ) Honorable ) Geary Kull, Petitioner-Appellant. ) Judge, presiding.

JUSTICE QUISH delivered the judgment of the court. Presiding Justice Navarro and Justice Ocasio concurred in the judgment.

ORDER

¶1 Held: The circuit court properly granted the State’s motion to dismiss petitioner’s petition for a certificate of innocence, as the petition was untimely under section 2-702(i) of the Code of Civil Procedure since it was filed more than two years after petitioner’s criminal case was dismissed.

¶2 Petitioner Coris Ashford appeals, pro se, from the order of the circuit court of Cook County

dismissing his petition for a certificate of innocence filed under section 2-702 of the Code of Civil

Procedure. 735 ILCS 5/2-702 (West 2024). For the following reasons, we affirm. No. 1-24-1387

¶3 While the record contains minimal information about petitioner’s underlying criminal case,

the following background is largely uncontested. Petitioner was charged in case 97 C 44081401

with a single count of unlawful possession of a weapon. He was convicted and served a sentence

of imprisonment. The statute under which petitioner was charged was later held to be

unconstitutional by our supreme court in People v. Aguilar, 2013 IL 112116, and its progeny. On

July 20, 2021, the circuit court vacated petitioner’s conviction. On November 18, 2021, the circuit

court granted petitioner’s request to expunge his conviction. The order states that, within 60 days

of receiving the order, “[t]he Illinois State Police must expunge or impound these records as

required by law.”

¶4 On January 26, 2024, petitioner filed a petition for a certificate of innocence. The State

filed a motion to dismiss the petition pursuant to section 2-619 of the Code of Civil Procedure (735

ILCS 5/2-619 (West 2024)), arguing that the petition was untimely since it was filed more than

two years after the dismissal or vacatur of the charges and therefore, did not meet the requirements

of section 2-702(i). 735 ILCS 5/2-702(i) (West 2024).

¶5 Petitioner filed a response to the motion to dismiss, arguing that his petition was timely

because the Illinois State Police (“ISP”) did not expunge his conviction from their records until

August 4, 2022, despite the requirement in the circuit court’s order to do so within 60 days. He

argued that since he filed his petition within two years of the date that the record of his conviction

was expunged by ISP, it was timely. He included a document showing that ISP denied his

application for a Firearm Owners Identification Card on July 25, 2022, stating that he was

ineligible due to a prior felony conviction. He also included records from ISP stating the “decision

date” that his conviction was expunged was August 4, 2022.

-2- No. 1-24-1387

¶6 The circuit court heard arguments on the State’s motion to dismiss and issued an oral ruling

dismissing the petition. The court found that the petition was untimely since it was filed more than

two years after petitioner’s conviction was vacated and expunged by the circuit court, even if it

was less than two years after ISP expunged the conviction from its records. This appeal follows.

¶7 On appeal, petitioner argues that the circuit court erred when it dismissed his petition as

untimely. He argues that he filed his petition within two years of when his criminal charges were

effectively dismissed, which, he asserts, is when ISP expunged the record of his conviction on

August 4, 2022. The State argues that the petition was properly dismissed as untimely because it

was filed more than two years after the circuit court’s orders vacating and expunging petitioner’s

conviction.

¶8 Section 2-702 of the Code of Civil Procedure allows for a person who is convicted and

imprisoned for an offense they did not commit to file a petition for a certificate of innocence. 735

ILCS 5/2-702(b) (West 2024). This includes convictions that are vacated due to the statute being

found unconstitutional. 735 ILCS 5/2-702(c)(2) (West 2024). Ordinarily, the determination of

whether a petitioner is entitled to a certificate of innocence is reviewed for an abuse of discretion.

Rudy v. People, 2013 IL App (1st) 113449, ¶ 11. However, since the circuit court granted the

State’s motion to dismiss the petition pursuant to section 2-619 of the Code of Civil Procedure,

our standard of review is de novo. Cahokia Unit School District No. 187 v. Pritzker, 2021 IL

126212, ¶ 24; People v. Chatmon, 2025 IL App (4th) 241481-U, ¶ 19.

¶9 Section 2-702(i) provides the following time limitation for the filing of a petition for a

certificate of innocence:

“Any person seeking a certificate of innocence under this Section based on the dismissal of an indictment or information or acquittal that occurred before the

-3- No. 1-24-1387

effective date of this amendatory Act of the 95th General Assembly shall file his or her petition within 2 years after the effective date of this amendatory Act of the 95th General Assembly. Any person seeking a certificate of innocence under this Section based on the dismissal of an indictment or information or acquittal that occurred on or after the effective date of this amendatory Act of the 95th General Assembly shall file his or her petition within 2 years after the dismissal.”

735 ILCS 5/2-702(i) (West 2024).

¶ 10 Since petitioner’s conviction was vacated after the statute’s effective date of September 22,

2008, the relevant issue is whether he filed his petition within two years of “the dismissal of [the]

indictment or information or acquittal.” Id.; Chatmon, 2025 IL App (4th) 241481-U, ¶ 23.

Petitioner argues that the dismissal was not effective until ISP expunged his conviction from their

records on August 4, 2022. However, when a statute is clear and unambiguous, we are not free to

depart from its plain language and meaning by reading into it exceptions, limitations, or conditions

that the legislature did not express. People v. Woodard, 175 Ill. 2d 435, 443 (1997). Based on its

plain language, section 2-702(i) refers only to the dismissal of the “indictment or information” or

an acquittal in the criminal case and not the date that the related criminal record is expunged. See

Chatmon, 2025 IL App (4th) 241481-U, ¶ 25 (two-year period to file petition for certificate of

innocence runs from date of acquittal or dismissal of indictment, rather than from the date the

petitioner sought to expunge the record). Therefore, we reject petitioner’s argument that the date

when ISP expunged the record of his conviction is the date his criminal case was “dismissed”

under section 2-702(i).

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Related

People v. Aguilar
2013 IL 112116 (Illinois Supreme Court, 2013)
People v. Woodard
677 N.E.2d 935 (Illinois Supreme Court, 1997)
Rudy v. People
2013 IL App (1st) 113449 (Appellate Court of Illinois, 2013)
People v. Holmes
2017 IL 120407 (Illinois Supreme Court, 2017)
Cahokia Unit School District No. 187 v. Pritzker
2021 IL 126212 (Illinois Supreme Court, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
2026 IL App (1st) 241387-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-ashford-illappct-2026.