People v. Cutler

2021 IL App (4th) 190443-U
CourtAppellate Court of Illinois
DecidedJuly 14, 2021
Docket4-19-0443
StatusUnpublished
Cited by1 cases

This text of 2021 IL App (4th) 190443-U (People v. Cutler) 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. Cutler, 2021 IL App (4th) 190443-U (Ill. Ct. App. 2021).

Opinion

NOTICE FILED This Order was filed under 2021 IL App (4th) 190443-U July 14, 2021 Supreme Court Rule 23 and Carla Bender is not precedent except in the NO. 4-19-0443 4th District Appellate limited circumstances Court, IL allowed under Rule 23(e)(1). IN THE APPELLATE COURT

OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from Plaintiff-Appellee, ) Circuit Court of v. ) Sangamon County ERIC CUTLER, ) No. 17CF338 Defendant-Appellant. ) ) Honorable ) Adam Giganti, ) Judge Presiding.

JUSTICE HOLDER WHITE delivered the judgment of the court. Justices DeArmond and Steigmann concurred in the judgment.

ORDER ¶1 Held: The appellate court remanded with directions where defense counsel failed to strictly comply with Illinois Supreme Court Rule 604(d) (eff. July 1, 2017).

¶2 On April 12, 2017, a grand jury indicted defendant, Eric Cutler, on four counts of

first degree murder (720 ILCS 5/9-1(a)(1), (a)(2) (West 2016)). On May 10, 2019, defendant

pleaded guilty to one count of first degree murder (720 ILCS 5/9-1(a)(2) (West 2016)), where

“defendant, having obtained the age of 18, without lawful justification struck [his son] M.C., age

2 months, about the head and body causing blunt force trauma, knowing said act created the

strong probability of death or great bodily harm to M.C., thereby causing the death of M.C.” In

exchange for defendant’s guilty plea, the State agreed to dismiss the remaining charges and

recommend a sentencing cap of 60 years’ imprisonment, although defendant was eligible for an

extended-term sentence of 20 to 100 years. ¶3 On June 4, 2019, defendant filed a pro se motion to withdraw his guilty plea. At a

June 6, 2019, hearing on defendant’s pro se motion, the trial court questioned defendant about

his claims of ineffective assistance of plea counsel and continued the matter for counsel to file a

certificate of compliance pursuant to Illinois Supreme Court Rule 604(d) (eff. July 1, 2017). On

June 14, 2019, defense counsel filed a certificate of compliance pursuant to Rule 604(d). Also,

following a June 14, 2019, hearing, the court denied defendant’s pro se motion to withdraw his

guilty plea.

¶4 On July 1, 2019, the trial court sentenced defendant to 60 years in prison.

Following sentencing, on July 1, 2019, defense counsel filed a second certificate of compliance

pursuant to Rule 604(d). Defense counsel also filed a motion to reconsider defendant’s sentence

and a second motion to withdraw defendant’s guilty plea. On July 2, 2019, the court denied both

motions.

¶5 Defendant appeals, arguing (1) the trial court erred in denying his motion to

withdraw his guilty plea where (a) the record shows his plea was not entered knowingly and

intelligently because defense counsel misunderstood the nature and consequences of his plea and

(b) his plea was not voluntary as the State’s actions improperly coerced him into the plea;

(2) defense counsel failed to strictly comply with the requirements of Rule 604(d), where counsel

failed to (a) review the transcript of the sentencing hearing, (b) amend the pleadings to

adequately represent defendant’s claims of error, and (c) provide necessary affidavits or

evidentiary support; and (3) the trial court erred by failing to conduct an appropriate Krankel

inquiry (see People v. Krankel, 102 Ill. 2d 181, 464 N.E.2d 1045 (1984)) where it did not

sufficiently question defendant or defense counsel regarding the basis of defendant’s claim that

counsel failed to explain an “open” plea. The State concedes defense counsel did not strictly

-2- comply with Rule 604(d) and requests remand only for strict compliance with Rule 604(d). We

remand with directions.

¶6 I. BACKGROUND

¶7 On April 12, 2017, a grand jury indicted defendant on four counts of first degree

murder (720 ILCS 5/9-1(a)(1), (a)(2) (West 2016)) (counts I-IV). The charges alleged defendant

caused the death of his two-month-old son, M.C.

¶8 A. Preliminary Hearing

¶9 During an April 23, 2019, status hearing, the State advised the trial court that

defendant had previously been inaccurately admonished on the maximum possible penalty for

the first three murder charges. Previously, defendant was incorrectly told he faced an extended

term of 20 to 60 years on the first three counts. The State indicated that because the victim was

under 12 years old at the time of death, defendant actually faced an extended term of 20 to 100

years in prison.

¶ 10 The State also informed the court that it made an offer agreeing not to seek an

extended sentence if defendant pleaded guilty before the present court date. After discussion,

and defense counsel expressing the need for more time to discuss the offer with defendant where

they were under the impression the sentencing range was 20 to 60 years in prison, the State

agreed to keep the offer available until the next court date of May 10, 2019. Then, defense

counsel clarified, stating “we’re calling it an offer, but it’s just the expression of a willingness not

to seek 60 to 100 if pleased [sic] open to—what count?” (Emphasis in original). The State

responded, “We don’t have a particular preference on the count.” Thereafter, the court asked the

State, “So where we’re at right now is that the offer from the State is a plea to any of the four

-3- counts and a cap of 60 years?” After the State responded in the affirmative, defense counsel

agreed that was also her understanding.

¶ 11 B. Guilty Plea

¶ 12 At a May 10, 2019, hearing, defense counsel informed the trial court that

defendant made two plea offers but the State rejected both offers, and the State “reassert[ed] their

prior offer of an open plea with a cap of 60.” Defense counsel stated that she explained the

State’s offer to defendant but “he had not given me any indication that he wishes to accept the

open plea.”

¶ 13 Defense counsel then made an oral motion to continue the trial date from May 13

to May 28 because she received several items of discovery from the State during the prior week

and believed she needed to review and discuss the items with defendant. The discovery items

included but were not limited to a report from the Department of Children and Family Services,

emails suggesting one of the paramedics did not follow proper procedures, and extraction reports

from two or three cell phones that belonged to defendant and M.C.’s mother. Defense counsel

estimated the cell phone records alone contained over 1000 pages of material. The State

objected to the continuance and argued, “there’s no new information here that the [d]efense

doesn’t already have[.]” After considering the arguments of both parties and case law submitted

by the State, the trial court denied defendant’s motion to continue.

¶ 14 The State then related, “[W]e discussed at the last pretrial our offer for a cap of 60

will expire at the end of this hearing. It might be best to inquire of the [d]efendant if there’s any

chance at this time that he wants to plead guilty.” The court asked defense counsel if she wished

to address the State’s offer, and counsel asked the court to address defendant directly. The State

then indicated as follows:

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Related

People v. Cutler
2023 IL App (4th) 220689-U (Appellate Court of Illinois, 2023)

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2021 IL App (4th) 190443-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-cutler-illappct-2021.