People v. Bryant

Appellate Court of Illinois·Decided May 18, 2026·No. 2-25-0323·Unpublished

Opinion

2026 IL App (2d) 250323-U No. 2-25-0323 Order filed May 18, 2026

NOTICE: This order was filed under Illinois Supreme Court Rule 23(b) and is not precedential except in the limited circumstances allowed under Rule 23(e)(1).

IN THE

APPELLATE COURT OF ILLINOIS

SECOND DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff-Appellee,

v.

WINFORD BRYANT, Defendant-Appellant.

Appeal from the Circuit Court of Lake County. Honorable James K. Booras, Judge, Presiding. No. 04-CF-2014

JUSTICE BIRKETT delivered the judgment of the court. Justices Hutchinson and Jorgensen concurred in the judgment.

ORDER

¶1 Held: We lack jurisdiction over this appeal because the notice of appeal was not timely filed and the time has passed for defendant to seek to file a late notice of appeal. Therefore, we grant appellate counsel’s motion to withdraw, and we dismiss this appeal.

¶2 Defendant, Winford Bryant, appeals from an order of the circuit court of Lake County

denying his pro se petition under section 2-1401 of the Code of Civil Procedure (735 ILCS 5/2-

1401 (West 2022)) for relief from his convictions of aggravated battery with a firearm (720 ILCS

5/12-4.2(a)(1) (West 2004)) and attempted first degree murder (id. §§ 8-4(a), 9-1(a)(1)). The

Office of the State Appellate Defender (OSAD) was appointed to represent defendant, but counsel

assigned to the case moved to withdraw, contending that we lacked jurisdiction over the appeal. We denied the motion without prejudice. Counsel subsequently filed an amended motion,

contending again that this appeal must be dismissed for lack of jurisdiction. We agree and therefore

grant counsel’s motion and dismiss the appeal.

¶3 I. BACKGROUND

¶4 On May 5, 2025, defendant filed his section 2-1401 petition. On May 6, 2025, the State

filed a written motion to dismiss or deny the petition. The record does not show that the motion

was served on defendant. The trial court heard the motion on May 8, 2025. Defendant was

incarcerated and not present at the hearing. After the trial court indicated that it was granting the

State’s motion, the prosecutor asked whether the court wanted a written order prepared. The court

responded, “Yes, so the clerk can notify the defendant.” The order denying the petition was filed

on May 9, 2025. There is no indication in the record that defendant was notified that his petition

was denied. On June 23, 2025, defendant wrote to the clerk to inquire about the status of his

petition. On July 25, 2025, defendant filed an unsigned notice of appeal from the order denying

the petition. On July 29, 2025, trial court appointed OSAD to represent defendant, and the clerk

filed a notice of appeal on defendant’s behalf from the order denying the petition.

¶5 On December 8, 2025, appellate counsel moved to withdraw per Pennsylvania v. Finley,

481 U.S. 551 (1987), and People v. Lee, 251 Ill. App. 3d 63 (1993). In his motion, counsel stated

that he read the record and found no issue of arguable merit. Counsel further stated that he advised

defendant of his opinion. Counsel supported his motion with a memorandum of law providing a

statement of facts, a list of potential issues, and arguments as to why those issues lacked arguable

merit. We advised defendant that he had 30 days to respond to the motion, but he did not do so.

In the motion, counsel contended that defendant’s notice of appeal was untimely and that there

were no grounds for seeking leave to file the late notice of appeal. Counsel based his jurisdictional

-2- argument on Illinois Supreme Court Rule 606 (eff. Apr. 15, 2024), which governs the perfection

of appeals in criminal cases. Rule 606(b) provides that, generally, the party’s notice of appeal must

be filed within 30 days after the entry of the final judgment from which the party appeals. Ill. S.

Ct. R. 606(b) (eff. Apr. 15, 2024). However, under Rule 606(c), a party may seek leave to file a

late notice of appeal:

“[O]n motion supported by a showing of reasonable excuse for failing to file a notice of

appeal on time filed in the reviewing court within 30 days of the expiration of the time for

filing the notice of appeal, or on motion supported by a showing by affidavit that there is

merit to the appeal and that the failure to file a notice of appeal on time was not due to

appellant's culpable negligence, filed in the reviewing court within six months of the

expiration of the time for filing the notice of appeal, in either case accompanied by the

proposed notice of appeal, the reviewing court may grant leave to appeal and order the

clerk to transmit the notice of appeal to the trial court for filing.” Ill. S. Ct. R. 606(c) (eff.

Apr. 15, 2024).

¶6 Counsel contended that defendant’s July 2025 notice of appeal was untimely under Rules

606(b) and (c). Counsel further explained that he found no meritorious basis for the appeal and

therefore sought to withdraw rather than attempt to perfect the appeal under Rule 606(c), which

was applicable 30 days after, but within 6 months of, the notice of appeal’s original due date.

¶7 Counsel’s argument assumed that Rule 606 applies to an appeal from the denial of a section

2-1401 petition challenging a criminal conviction. Although relief under section 2-1401 is

available in criminal cases, that provision creates a civil remedy. People v. Vincent, 226 Ill. 2d 1,

8 (2007). Thus, because we were unwilling to accept counsel’s assumption, we denied the motion

to withdraw without prejudice to counsel filing a new motion to withdraw addressing the source

-3- of our jurisdiction over this appeal. Our order denying the motion to withdraw further provided,

“If counsel chooses to file a new motion to withdraw, that motion shall[ ] *** indicate whether

defendant was notified of the order from which this appeal is taken and, if not, whether the lack of

notice has any jurisdictional significance.” People v. Bryant, No. 2-25-0323 (Jan. 28, 2026)

(unpublished minute order).

¶8 Counsel filed an amended motion to withdraw, and we advised defendant that he had 30

days to respond to the amended motion. Defendant did not file a response, and the time for doing

so has lapsed. In the amended motion, counsel now asserts that Illinois Supreme Court Rule 303

(eff. July 1, 2017), governing civil appeals, applies here. Counsel again argues that we lack

jurisdiction.

¶9 II. ANALYSIS

¶ 10 It is well established that “ ‘[t]he timely filing of a notice of appeal is both jurisdictional

and mandatory.’ ” People v. Tapp, 2012 IL App (4th) 100664, ¶ 3 (quoting Secura Insurance Co.

v. Illinois Farmers Insurance Co., 232 Ill. 2d 209, 213 (2009)). “Unless the appealing party has

properly filed a notice of appeal, a reviewing court lacks jurisdiction over the appeal and must

dismiss it.” Id. Moreover, we may not address the merits of an appeal over which we lack

jurisdiction. Cf. People v. Vara, 2018 IL 121823, ¶ 30 (“Where the appellate court has addressed

the merits of a case over which it had no jurisdiction, we must vacate that court’s judgment and

dismiss the appeal.”).

¶ 11 Leaving aside, for the moment, the question of whether the civil or criminal appeal rules

apply to this case, we encourage appointed attorneys representing defendants in criminal appeals

Free access — add to your briefcase to read the full text and ask questions with AI

People v. Bryant, (Ill. Ct. App. 2026).

People v. Bryant (People v. Bryant) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Pennsylvania v. Finley
481 U.S. 551 (Supreme Court, 1987)
People v. Lyles
840 N.E.2d 1187 (Illinois Supreme Court, 2005)
Secura Insurance v. Illinois Farmers Insurance
902 N.E.2d 662 (Illinois Supreme Court, 2009)
People v. Lee
621 N.E.2d 287 (Appellate Court of Illinois, 1993)
Granite City Lodge No. 272 v. City of Granite City
565 N.E.2d 929 (Illinois Supreme Court, 1990)
People v. Vincent
871 N.E.2d 17 (Illinois Supreme Court, 2007)
People v. Tapp
2012 IL App (4th) 100664 (Appellate Court of Illinois, 2012)
People v. Vara
2018 IL 121823 (Illinois Supreme Court, 2018)