People v. Daniels

2021 IL App (2d) 180705-U
CourtAppellate Court of Illinois
DecidedFebruary 23, 2021
Docket2-18-0705
StatusUnpublished

This text of 2021 IL App (2d) 180705-U (People v. Daniels) 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. Daniels, 2021 IL App (2d) 180705-U (Ill. Ct. App. 2021).

Opinion

2021 IL App (2d) 180705-U No. 2-18-0705 Order filed February 23, 2021

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

IN THE

APPELLATE COURT OF ILLINOIS

SECOND DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE ) Appeal from the Circuit Court OF ILLINOIS, ) of Lake County. ) Plaintiff-Appellee, ) ) v. ) No. 12-CF-3315 ) JAMES K. DANIELS, ) Honorable ) Mark L. Levitt, Defendant-Appellant. ) Judge, Presiding. ______________________________________________________________________________

JUSTICE HUDSON delivered the judgment of the court. Justices McLaren and Brennan concurred in the judgment.

ORDER

¶1 Held: Postconviction counsel failed to file a certificate under Rule 651(c), and the record did not affirmatively demonstrate compliance with the rule. Specifically, there was no showing that counsel reviewed the record of the trial court proceedings. Vacated and remanded for compliance with the rule.

¶2 On August 4, 2015, defendant, James K. Daniels, filed a pro se postconviction petition

under the Post-Conviction Hearing Act (Act) (725 ILCS 5/122 et seq. (West 2014)), seeking relief

from his convictions of burglary (720 ILCS 5/19-1(a) (West 2012)). On December 1, 2015, the

trial court appointed the Lake County Public Defender’s Office to represent defendant in the

postconviction proceedings. On May 4, 2017, the State was granted leave to file its motion to 2021 IL App (2d) 180705-U

dismiss defendant’s petition. Postconviction counsel made no amendments to defendant’s petition

and did not file a response to the State’s motion. On August 23, 2018, the court granted the State’s

motion and dismissed the petition. On appeal, defendant argues that the second-stage dismissal of

his petition must be vacated and the matter remanded for further proceedings, with the appointment

of new counsel, because postconviction counsel did not file a certificate pursuant to Illinois

Supreme Court Rule 651(c) (eff. July 1, 2017) and the record does not otherwise show compliance

with the rule. We agree.

¶3 The Act provides a method by which persons under criminal sentence can assert that their

convictions were the result of a substantial denial of their federal or state constitutional rights. 725

ILCS 5/122-1(a)(1) (West 2018); People v. Kirkpatrick, 2012 IL App (2d) 100898, ¶ 10. The Act

establishes a three-stage process for the adjudication of a postconviction petition. People v.

Boclair, 202 Ill. 2d 89, 99 (2002). At the first stage, the trial court has 90 days to review the petition

without the input of any party, and it may summarily dismiss the petition if it finds it to be frivolous

or patently without merit. 725 ILCS 5/122-2.1(a)(2) (West 2018); Kirkpatrick, 2012 IL App (2d)

100898, ¶ 11. If a petition is not summarily dismissed at the first stage, it advances to the second

stage, where an indigent petitioner can obtain appointed counsel. 725 ILCS 5/122-2.1(b), 122-4

(West 2018); Kirkpatrick, 2012 IL App (2d) 100898, ¶ 12. “[A]fter counsel has made any

necessary amendments to the petition, the State may move to dismiss it. [Citations.] If the State

moves to dismiss, the trial court may hold a dismissal hearing, which is still part of the second

stage. [Citation.]” Kirkpatrick, 2012 IL App (2d) 100898, ¶ 13. If the defendant makes a

substantial showing of a constitutional violation, the petition advances to the third stage where the

trial court conducts an evidentiary hearing. 725 ILCS 5/122-6 (West 2018); Boclair, 202 Ill. 2d at

100.

-2- 2021 IL App (2d) 180705-U

¶4 There is no constitutional right to effective assistance of counsel in postconviction

proceedings. People v. Suarez, 224 Ill. 2d 37, 42 (2007). The right to counsel in postconviction

proceedings is statutory (725 ILCS 5/122-4 (West 2018)), and the Act provides for a reasonable

level of assistance. 725 ILCS 5/122-1 et seq. (West 2018)); Suarez, 224 Ill. 2d at 42. Rule 651(c)

(eff. July 1, 2017) is meant to ensure that petitioners receive a reasonable level of assistance.

Suarez, 224 Ill. 2d at 42. The rule requires:

“The record filed in th[e] court shall contain a showing, which may be made by the

certificate of petitioner’s attorney, that the attorney has consulted with petitioner by phone,

mail, electronic means or in person to ascertain his or her contentions of deprivation of

constitutional rights, has examined the record of the proceedings at the trial, and has made

any amendments to the petitions filed pro se that are necessary for an adequate presentation

of petitioner’s contentions.” Ill. S. Ct. Rule 651(c) (eff. July 1, 2017).

¶5 Substantial compliance with the duties set forth in Rule 651(c) is mandatory. People v.

Lander, 215 Ill. 2d 577, 584 (2005). Postconviction counsel may show compliance by filing a Rule

651(c) certificate. Id. Filing a Rule 651(c) certificate gives rise to a rebuttable presumption that

counsel complied with the rule and provided reasonable assistance. People v. Profit, 2012 IL App

(1st) 101307, ¶ 19. Failure to file a Rule 651(c) certificate is harmless error if the record

demonstrates that counsel adequately fulfilled the required duties. Lander, 215 Ill. 2d at 584. While

failure to certify compliance by filing a certificate can be harmless error (id.), failure to actually

comply with the rule cannot (id. at 585). Once a petitioner survives the first stage, he is entitled to

the reasonable assistance of counsel to help him adequately present his claims. Suarez, 224 Ill. 2d

at 46. The statute cannot fulfill its purpose without requiring counsel to provide this basic level of

-3- 2021 IL App (2d) 180705-U

assistance. Id. Thus, where counsel fails to provide reasonable assistance, remand is required,

regardless of whether the claims raised in the pro se and amended petitions are viable. Id. at 47.

¶6 Here, postconviction counsel did not file a Rule 651(c) certificate; therefore, there is no

presumption that defendant received reasonable assistance of counsel. Thus, the issue is whether,

despite counsel’s failure to file a Rule 651(c) certificate, the record demonstrates that counsel

complied with the requirements of Rule 651(c). It does not.

¶7 Under Rule 651(c) (eff. July 1, 2017), postconviction counsel must “examine[] the record

of the proceedings at the trial.” We agree with defendant that there is no affirmative showing in

the record that postconviction counsel did so here. The State argues otherwise, pointing to two

comments made by counsel. On April 22, 2016, counsel asked the trial court for “a little bit more

time to review everything.” On March 20, 2017, after six continuances, counsel stated: “I am ready

to proceed to [the] second stage. I will not file anything, but I’ll proceed on his previously filed

motion—or PCP.” The State asserts that, by these comments, counsel “inform[ed] the court that

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Related

People v. Suarez
862 N.E.2d 977 (Illinois Supreme Court, 2007)
People v. Boclair
789 N.E.2d 734 (Illinois Supreme Court, 2002)
People v. Jennings
802 N.E.2d 867 (Appellate Court of Illinois, 2003)
People v. Lander
831 N.E.2d 596 (Illinois Supreme Court, 2005)
People v. Kirkpatrick
2012 IL App (2d) 100898 (Appellate Court of Illinois, 2012)
People v. Profit
2012 IL App (1st) 101307 (Appellate Court of Illinois, 2012)
People v. Schlosser
2017 IL App (1st) 150355 (Appellate Court of Illinois, 2017)

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Bluebook (online)
2021 IL App (2d) 180705-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-daniels-illappct-2021.