People v. Eaton

2026 IL App (4th) 250680-U
CourtAppellate Court of Illinois
DecidedFebruary 23, 2026
Docket4-25-0680
StatusUnpublished

This text of 2026 IL App (4th) 250680-U (People v. Eaton) 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. Eaton, 2026 IL App (4th) 250680-U (Ill. Ct. App. 2026).

Opinion

NOTICE 2026 IL App (4th) 250680-U This Order was filed under FILED Supreme Court Rule 23 and is February 23, 2026 not precedent except in the NO. 4-25-0680 Carla Bender limited circumstances allowed 4th District Appellate under Rule 23(e)(1). IN THE APPELLATE COURT Court, IL

OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) Stark County EDWARD E. EATON JR., ) No. 13CF22 Defendant-Appellant. ) ) Honorable ) James A. Mack, ) Judge Presiding.

JUSTICE LANNERD delivered the judgment of the court. Justices Zenoff and Harris concurred in the judgment.

ORDER

¶1 Held: The trial court did not abuse its discretion in sentencing defendant to 21 years’ imprisonment for predatory criminal sexual assault of a child.

¶2 In June 2014, defendant, Edward E. Eaton Jr., pleaded guilty to predatory criminal

sexual assault of a child (720 ILCS 5/11-1.40(a)(1) (West 2012)) and was sentenced to 24 years’

imprisonment. Following proceedings under the Post-Conviction Hearing Act (Act) (725 ILCS

5/122-1 et seq. (West 2016)), the trial court granted defendant postconviction relief and allowed

him to file a motion to reconsider his sentence.

¶3 After multiple remands for compliance with Illinois Supreme Court Rule 604(d)

(eff. July 1, 2017), postplea counsel filed a new Rule 604(d) certificate and an amended motion to

reconsider defendant’s sentence. See People v. Eaton, No. 3-21-0088 (Jan. 11, 2022) (unpublished

order); People v. Eaton, 2024 IL App (4th) 230859-U. The trial court held a hearing on the amended motion to reconsider on February 14, 2025. After hearing the parties’ arguments, the

court reduced defendant’s sentence to 21 years’ imprisonment. Postplea counsel then filed a

motion to reconsider the 21-year sentence. Following a hearing, the court denied the motion to

reconsider. Defendant appeals, arguing his sentence is excessive because the court failed to give

proper weight to certain mitigating factors. We affirm.

¶4 I. BACKGROUND

¶5 In September 2013, defendant was charged with two counts of predatory criminal

sexual assault of a child, a Class X felony (720 ILCS 5/11-1.40(a)(1) (West 2012)). Defendant

subsequently entered a plea of guilty to one count, and the other count was dismissed. The trial

court sentenced defendant to 24 years’ imprisonment. Defendant did not file a direct appeal.

¶6 On June 27, 2016, defendant filed a postconviction petition under the Act pertaining

to plea counsel’s failure to file a motion to reconsider his sentence. The trial court granted

defendant postconviction relief in October 2019 and allowed him to file a motion to reconsider his

sentence. Postplea counsel subsequently filed a motion to reconsider defendant’s sentence but did

not file a certificate of compliance in accordance with Rule 604(d).

¶7 In February 2021, the trial court denied defendant’s motion to reconsider his

sentence following a hearing. On appeal, the Appellate Court, Third District, granted defendant’s

unopposed motion to remand for compliance with Rule 604(d) and dismissed the appeal. Eaton,

No. 3-21-0088 (Jan. 11, 2022) (unpublished order).

¶8 On remand, the trial court allowed postplea counsel to file a Rule 604(d) certificate

nunc pro tunc to the date the motion to reconsider counsel sentence was filed. No new hearing was

held on the motion to reconsider.

¶9 In August 2024, this court vacated the denial of defendant’s motion to reconsider

-2- and remanded for new postplea proceedings and strict compliance with Rule 604(d). Eaton, 2024

IL App (4th) 230859-U, ¶ 22.

¶ 10 On remand, postplea counsel filed a new Rule 604(d) certificate and an amended

motion to reconsider defendant’s sentence. The amended motion asserted the original sentencing

court improperly considered the psychological harm it had witnessed in other sexual assault cases

when sentencing defendant in this case. The motion also raised defendant’s history of mental

disability as mitigating evidence omitted by plea counsel. Following a hearing, the trial court ruled

on the amended motion:

“I reviewed the charges, the plea, [the] appellate opinion that brings us here today,

the motion to reconsider, response to the motion to reconsider. So I have reviewed

the original [presentence investigation report (PSI)] prepared in this case, sections

of [the] transcript as well as prior words from the appellate court.

In reviewing all of these—[the] case law that’s cited, I do believe that

[defendant’s] sentence was excessive. I believe that the original sentencing judge

put—although he can consider harm to the victim, his statements went beyond that

and beyond what was presented at the sentencing hearing.

Addressing the other matters brought up in the motion brought up in the

motion, [that] there was mitigating evidence *** not put into evidence by the

original attorney. However, those items were all in the [PSI] in regard to diminished

capacity, the accident, the finding of disability and special education classes, and

the like, prior to this.”

¶ 11 The trial court reduced defendant’s sentence to 21 years’ imprisonment. Postplea

counsel then filed a new motion to reconsider defendant’s 21-year sentence and an accompanying

-3- Rule 604(d) certificate. The court denied the motion to reconsider.

¶ 12 This appeal followed.

¶ 13 II. ANALYSIS

¶ 14 On appeal, defendant argues his 21-year sentence is excessive. Specifically,

defendant contends the trial court failed to give proper weight to several mitigating factors,

including his history of mental illness and substance abuse, his traumatic upbringing, a previous

finding of unfitness, and his guilty plea.

¶ 15 A trial court’s sentence must be based on “the particular circumstances of the case,

including (1) the defendant’s history, character, and rehabilitative potential; (2) the seriousness of

the offense; (3) the need to protect society; and (4) the need for punishment and deterrence.”

People v. Sturgeon, 2019 IL App (4th) 170035, ¶ 102. Additionally, the Unified Code of

Corrections (Unified Code) (730 ILCS 5/1-1-1 et seq. (West 2012)) sets forth the mitigating and

aggravating factors the court must consider when determining an appropriate sentence. See

Sturgeon, 2019 IL App (4th) 170035, ¶ 105. However, “[t]he weight to be given to any proper

factor *** is left to the sound discretion of the trial court and will not be disturbed on appeal absent

an abuse of discretion.” (Emphasis omitted.) Id. ¶ 104. “A trial court’s sentence is an abuse of

discretion only if it is greatly at odds with the spirit and purpose of the law or is manifestly

disproportionate to the nature of the offense.” People v. Klein, 2022 IL App (4th) 200599, ¶ 38.

Moreover, “[a] sentence imposed within the statutory range provided by the legislature is

presumed to be proper.” Sturgeon, 2019 IL App (4th) 170035, ¶ 104. “In considering the propriety

of a sentence, the reviewing court must proceed with great caution and must not substitute its

judgment for that of the trial court merely because it would have weighed the factors differently.”

People v. Fern, 189 Ill. 2d 48, 53 (1999).

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Related

People v. Pippen
756 N.E.2d 474 (Appellate Court of Illinois, 2001)
People v. Mertz
842 N.E.2d 618 (Illinois Supreme Court, 2005)
People v. Fern
723 N.E.2d 207 (Illinois Supreme Court, 1999)
People v. Alexander
940 N.E.2d 1062 (Illinois Supreme Court, 2010)
People v. Halerewicz
2013 IL App (4th) 120388 (Appellate Court of Illinois, 2014)
People v. Sturgeon
2019 IL App (4th) 170035 (Appellate Court of Illinois, 2019)
People v. Klein
2022 IL App (4th) 200599 (Appellate Court of Illinois, 2022)
People v. O'Neal
2021 IL App (4th) 200014 (Appellate Court of Illinois, 2021)
People v. Eaton
2024 IL App (4th) 230859-U (Appellate Court of Illinois, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
2026 IL App (4th) 250680-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-eaton-illappct-2026.