People v. Billups-Dryer

2022 IL App (1st) 191947-U
CourtAppellate Court of Illinois
DecidedNovember 23, 2022
Docket1-19-1947
StatusUnpublished
Cited by1 cases

This text of 2022 IL App (1st) 191947-U (People v. Billups-Dryer) 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. Billups-Dryer, 2022 IL App (1st) 191947-U (Ill. Ct. App. 2022).

Opinion

2022 IL App (1st) 191947-U No. 1-19-1947 Order filed November 23, 2022 Sixth Division

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 Plaintiff-Appellee, ) Cook County. ) v. ) No. 18 C6 60468 ) ANDREA BILLUPS-DRYER, ) The Honorable ) Carl B. Boyd, Defendant-Appellant. ) Judge, presiding.

JUSTICE TAILOR delivered the judgment of the court. Justices Walker and Oden Johnson concurred in the judgment.

ORDER

¶1 Held: Defendant’s conviction for theft is reversed and the cause remanded for a new trial where the trial court failed to substantially admonish defendant under Illinois Supreme Court Rule 401(a) before accepting her waiver of counsel.

¶2 Following a jury trial where she proceeded pro se, defendant Andrea Billups-Dryer was

found guilty of felony theft (720 ILCS 5/16-1(a)(2)(A) (West 2016)), and the trial court sentenced

her to two years’ probation and ordered her to pay restitution. On appeal, Billups-Dryer contends

her waiver of counsel was ineffective because the trial court failed to admonish her as required by No. 1-19-1947

Illinois Supreme Court Rule 401(a) (eff. July 1, 1984). We agree, and therefore reverse and remand

for a new trial.

¶3 Billups-Dryer was charged with one count of Class 3 felony theft for allegedly posing as

the landlord of a property—which she did not own or in which she did not otherwise have an

interest—so that she could obtain rent from a tenant. The information alleged that from September

1, 2016, through May 25, 2017, Billups-Dryer deceptively obtained between $500 and $10,000

from Michele Patterson-Joseph with the intent to permanently deprive her of that money.

¶4 The half-sheet reflects that the trial court granted a private attorney leave to file an

appearance for Billups-Dryer on July 25, 2018. The half-sheet for August 13, 2018, however, states

that Billups-Dryer “is allowed to proceed pro-se.” 1

¶5 During arraignment on September 14, 2018, Billups-Dryer appeared without counsel and

informed the trial court that she was “self-representing.” The trial court advised that Billups-Dryer

was charged with a Class 3 felony and asked whether she knew “what a Class 3 felony is?” Billups-

Dryer answered affirmatively. The trial court then stated that it must ask “a few questions if you’re

trying to waive your right to a lawyer,” including Billups-Dryer’s age and education. Billups-Dryer

stated that she was 51 years old and completed two years of college. The trial court also asked

whether Billups-Dryer had “any prior involvement in legal proceedings,” and she answered

affirmatively.

1 The record on appeal does not include a report of proceedings for July 25, 2018, or August 13, 2018.

-2- No. 1-19-1947

¶6 Then the following colloquy occurred:

“THE COURT: Do you know that a self-representative defense is not a simple

matter of telling your story. It requires appearance [sic] to various technical rules governing

the conduct of a trial; do you know that?

[BILLUPS-DRYER]: Yes, your Honor.

THE COURT: A lawyer has substantial experience and training in trial procedures

and the prosecution will be represented by an experienced attorney; do you know that?

THE COURT: A person unfamiliar with legal procedures may allow the prosecutor

an advantage by failing to make objections to inadmissible evidence; do you know that?

THE COURT: Also, if you select a jury trial, you may not make effective usage of

such rights as your voir dire or questioning of jurors; do you know that?

THE COURT: *** [I]f you’re not represented by a lawyer you may make tactical

decisions that produce unintended consequences; are you aware of that?

THE COURT: Now, a defendant proceeding pro se will not be allowed to complain

on appeal about the competency of his or her representation; are you aware of that?

[BILLUPS-DRYER]: Sure, your Honor.

THE COURT: And the effectiveness of your defense may be diminished by your

dual roll [sic] as both the lawyer and the defendant or the accused; do you understand that?

-3- No. 1-19-1947

THE COURT: Because you are representing yourself, you also realize that you will

receive no special consideration from the Court?

THE COURT: And also you will receive no extra time for preparation or greater

time merely because you are pro se; do you understand that?

THE COURT: I also have to ask you whether you are aware that a lawyer can

render important assistance by determining the existence of possible defenses to your

particular charge; are you aware of that?

THE COURT: Now, a lawyer could assist you in possibly having your charges

reduced or you receiving a lesser penalty; are you aware of that?

THE COURT: Now, also if you are represented by a lawyer and this matter resulted

in a conviction, then the lawyer could present evidence to the Court that may result in a

lower or lesser sentence; are you aware of that?

[BILLUPS-DRYER]: Yes, your Honor.”

¶7 The trial court further advised that if Billups-Dryer proceeded pro se, she might not have

the opportunity “to change [her] mind during the trial and ask for a lawyer.” Billups-Dryer

responded that she understood. The trial court stated that Billups-Dryer received the “401

admonishments” and would be “representing [her]self.” Billups-Dryer acknowledged the trial

court’s statement. The trial court then handed Billups-Dryer a copy of the information charging

-4- No. 1-19-1947

her with Class 3 felony theft from September 1, 2016, through May 25, 2017. Billups-Dryer agreed

to waive a reading of the indictment and pleaded not guilty.

¶8 Prior to trial, Billups-Dryer filed numerous motions, subpoenas, and affidavits, including

challenges to the legal sufficiency of the theft charge, motions in limine, and responses to the

State’s discovery requests and motions in limine.

¶9 On April 22, 2019, after the parties argued their motions in limine, the trial court told

Billups-Dryer that she was charged with a “Class 3 offense” with a sentencing range of “two to

five year[s’]” imprisonment. The trial court asked whether the State would offer a plea bargain.

The State then offered Billups-Dryer one year of probation with no restitution.

¶ 10 The trial court stated that the cause would be continued to the next day for Billups-Dryer

to consider the offer. Billups-Dryer then orally moved to dismiss the case “for lack of a sworn

complainant [sic] by an injured party.” The trial court denied Billups-Dryers motion. Billups-Dryer

then moved for the appointment of “constitutional counsel,” stating that if the matter proceeded to

trial, she “may need someone to assist” with her testimony and with paperwork.

¶ 11 Then the following colloquy occurred:

“THE COURT: Now, Ms. Billups, we had this discussion awhile [sic] ago. I think

this is your second time asking for someone to assist you. I admonished you pursuant to

Supreme Court Rule 401. I told you at that time that I would probably not be appointing a

lawyer to help you with this case.

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Related

People v. Billups-Dryer
2025 IL App (1st) 240221 (Appellate Court of Illinois, 2025)

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Bluebook (online)
2022 IL App (1st) 191947-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-billups-dryer-illappct-2022.