People v. Banks

2020 IL App (5th) 170381-U
Appellate Court of Illinois·Decided May 21, 2020·No. 5-17-0381·Unpublished·Cited by 1 cases

Opinion

NOTICE 2020 IL App (5th) 170381-U NOTICE Decision filed 05/21/20. The This order was filed under text of this decision may be NO. 5-17-0381 Supreme Court Rule 23 and changed or corrected prior to may not be cited as precedent the filing of a Petition for by any party except in the Rehearing or the disposition of IN THE limited circumstances allowed the same. under Rule 23(e)(1).

APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ________________________________________________________________________

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Madison County. ) v. ) No. 88-CF-641 ) WILLIE BANKS JR., ) Honorable ) Jennifer L. Hightower, Defendant-Appellant. ) Judge, presiding. ________________________________________________________________________

JUSTICE BOIE delivered the judgment of the court. Justices Cates and Barberis concurred in the judgment.

ORDER

¶1 Held: The circuit court’s dismissal of the defendant’s section 2-1401 petition two days after the State filed a motion to dismiss and before the defendant had notice of and an opportunity to respond to the motion to dismiss denied the defendant procedural due process.

¶2 After a bench trial, the circuit court found the defendant, Willie Banks Jr., guilty of

two counts of armed robbery. Prior to sentencing, the circuit court also found that the

defendant qualified to be sentenced as a habitual criminal pursuant to the Habitual Criminal

Act (Ill. Rev. Stat. 1987, ch. 38, ¶ 33B-2). The circuit court, therefore, sentenced the

1 defendant to natural life in prison. On direct appeal, this court affirmed the defendant’s

conviction and sentence. People v. Banks, 212 Ill. App. 3d 105 (1991).

¶3 The defendant subsequently filed a pro se petition pursuant to section 2-1401 of the

Code of Civil Procedure (Code) (section 2-1401 petition) (735 ILCS 5/2-1401 (West

2016)), arguing that the Habitual Criminal Act was invalidly and illegally applied in his

case. The defendant’s allegations focused on the State’s use of three armed robbery

convictions that occurred in 1973, when the defendant was 15 years old, as part of the basis

for qualifying him to be sentenced under the Habitual Criminal Act. The defendant further

alleged that the State’s fraudulent concealment of its improper use of the convictions

hindered him from discovering the invalid and illegal application of the Habitual Criminal

Act in his case.

¶4 The State filed a motion to dismiss the defendant’s section 2-1401 petition. Two

days later the circuit court granted the State’s motion and dismissed the defendant’s petition

without affording the defendant an opportunity to respond to the motion. The defendant

now appeals and argues that he was denied due process because he was not allowed a

meaningful opportunity to respond to the motion to dismiss. In addition, the defendant

argues that the circuit court improperly dismissed his petition before it was “ripe for

adjudication.” For the following reasons, we agree with the defendant’s due process claim

and remand for further proceedings consistent with this decision.

2 ¶5 BACKGROUND

¶6 The defendant’s natural life sentence in this case stems from convictions entered on

January 26, 1989. After a bench trial, the circuit court found the defendant guilty of two

counts of armed robbery. Prior to sentencing, and pursuant to section 33B-2 of the Habitual

Criminal Act (Ill. Rev. Stat. 1987, ch. 38, ¶ 33B-2), the State filed a notice indicating that

the defendant qualified to be sentenced as a habitual criminal, and set out the defendant’s

prior convictions which included the three convictions for armed robbery in April 1973

and a conviction for armed robbery in April 1978.

¶7 The defendant’s presentencing investigation (PSI) report was filed on February 28,

1989. The PSI report included a section reflecting the defendant’s history of delinquency

and/or criminality. That section described the 1973 and 1978 convictions as follows. Under

the heading “Juvenile,” the PSI report stated that in 1973 the State filed a supplemental

petition in a pending juvenile proceeding alleging that the defendant committed armed

robbery and that the defendant was “[c]ertified to stand trial as an adult.” Under the heading

“Adult,” the PSI report indicated that the defendant was convicted of armed robbery in

1973 and sentenced to “4 to 6 years Illinois Department of Corrections, Juvenile Division.”

The PSI report also listed the armed robbery conviction from 1978 under the “Adult”

heading.

¶8 On April 25, 1989, the circuit court conducted a hearing to determine whether the

defendant qualified as a habitual offender. At the hearing, an employee of the Madison

County circuit clerk’s office identified certified copies of armed robbery convictions of 3 “Willie Banks” in the three 1973 criminal cases. The clerk also identified a certified copy

of the armed robbery conviction for “Willie Banks” in 1978.

¶9 An assistant state’s attorney testified that he prosecuted the defendant in the 1978

armed robbery case. He identified the defendant as the Willie Banks he prosecuted. A

police officer employed with the City of Alton testified that he participated in the

investigations of the 1973 and 1978 armed robberies that led to the convictions in the 1973

and 1978 cases. He identified the defendant as the Willie Banks that was convicted in those

cases.

¶ 10 Based on this evidence, the State argued that natural life in prison was the only

sentencing option because the defendant had been convicted of three Class X felonies. The

defense argued that the State failed to carry its burden under the Habitual Criminal Act

because the certified convictions for the 1973 offenses did not include any age or other

identity indicators of the person convicted in those offenses other than “Willie Banks.” In

addition, the defense noted that the defendant would have been 15 years old in 1973 and

that the State failed to prove that the defendant “was certified to stand trial as an adult,

which would be an element of that offense.”

¶ 11 On August 15, 1989, the circuit court entered an order finding that the prior armed

robbery convictions from 1973 and 1978 qualified the defendant as a habitual criminal

under the Habitual Criminal Act. The defendant subsequently filed a motion requesting the

circuit court to declare the Habitual Criminal Act to be unconstitutional. The circuit court

denied the defendant’s motion and sentenced the defendant to natural life in prison as 4 required by section 33B-1(e) of the Habitual Criminal Act (Ill. Rev. Stat. 1987, ch. 38,

¶ 33B-1(e)). In rejecting the defendant’s challenges to the statute at the sentencing hearing,

the circuit court stated that, after reading the statute, it could not find anything that would

prohibit the Habitual Criminal Act from being applied to a defendant who was “tried as an

adult even though that person may have been a juvenile at the time.” The circuit court,

therefore, sentenced the defendant to natural life in prison without the possibility of parole.

¶ 12 The defendant filed a direct appeal of his conviction and sentence, arguing that he

should not have been qualified as a habitual criminal because he was only 15 at the time of

the first armed robbery convictions. People v. Banks, 212 Ill. App. 3d 105, 106 (1991). He

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