People v. Garrett

2025 IL App (1st) 231675-U
CourtAppellate Court of Illinois
DecidedMarch 14, 2025
Docket1-23-1675
StatusUnpublished

This text of 2025 IL App (1st) 231675-U (People v. Garrett) 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. Garrett, 2025 IL App (1st) 231675-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 231675-U No. 1-23-1675 Order filed March 14, 2025 Fifth 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. 17 CR 12492 ) OSCAR GARRETT, ) Honorable ) James Michael Obbish, Defendant-Appellant. ) Judge, Presiding.

JUSTICE ODEN JOHNSON delivered the judgment of the court. Justices Mitchell and Navarro concurred in the judgment.

ORDER

¶1 Held: The trial court did not abuse its discretion in denying defendant’s motion for continuance for new counsel when defendant sought to change counsel the week before trial and six years after defendant’s criminal proceedings began and where the trial court had previously indicated to defendant that he would only allow new counsel to enter the case was if new counsel was ready to proceed with the scheduled trial date.

¶2 Following a jury trial, defendant Oscar Garrett was found guilty of theft over $100,000;

identity theft over $100,000; identity theft $10,000 to $100,000; mail fraud; wire fraud; forgery by No. 1-23-1675

delivery; and income tax fraud. Defendant was subsequently sentenced to 13 years’ imprisonment

on one count of theft over $100,000. On appeal, defendant raises a single issue: whether his

constitutional right to counsel of his choice was violated when the trial court denied defense

counsel’s motion to withdraw from the case and denied new counsel’s motion to file an appearance

on his behalf and proceed with defendant’s case. For the following reasons, we affirm.

¶3 Briefly stated, in September 2017, defendant was charged with numerous counts related to

multiple state tax filings that he prepared for his paying clients dating back to 2015. As noted

above, defendant was found guilty by a jury of multiple offenses.

¶4 Defendant was represented by attorney Shelly Prusak and attorney Tracey Harkins between

September 2017 and his 2023 trial and posttrial motions. From the end of 2017 through early 2020,

the record reflects that the case was continued many times by agreement. Court closures due to the

COVID-19 Pandemic further delayed the case during 2020, and additional agreed continuances

occurred through 2021. At a September 7, 2021, status hearing, the trial court set a status

conference for plea negotiations. Several other plea conferences ensued later in 2021 and at no

time did defendant notify the trial court that he had an issue with his attorneys. On January 11,

2022, attorney Prusak notified the trial court that defendant rejected the plea offer, and the trial

court set a pretrial date for March 2022, and an April 2022 trial date. The trial date was

subsequently pushed to May 2022, then to July 2022. Again, defendant was present at those various

status hearings and did not express any complaints about his attorneys. At subsequent status

hearings which discussed evidentiary issues and reset the trial date, defendant was present and

expressed no complaints about his attorneys. The same scenarios occurred at the beginning of 2023

and the trial date was subsequently reset for April 24, 2023.

-2- No. 1-23-1675

¶5 On April 17, 2023, the week before trial was scheduled to begin, defendant told attorney

Harkins that he wanted a new attorney. Attorney Harkins notified the trial court and the prosecutor

of defendant’s wishes, and the trial court asked the parties to pick a date that week to hear Attorney

Harkins’ motion to withdraw. The court also directed Attorney Harkins to tell defendant that his

new attorney needed to appear in person at that hearing and must be prepared to begin the jury

trial as scheduled on April 24, 2023. Attorney Harkins subsequently filed a motion to withdraw,

and a hearing was set for April 19, 2023.

¶6 While defendant and Attorney Harkins were present for the hearing, defendant’s

prospective counsel did not appear. Defendant explained that he misunderstood the message from

Attorney Harkins about the date of the hearing, he had not yet retained new counsel and said he

intended to retain either an attorney who had previously done real estate work for him or another

attorney. The trial court asked defendant why he wanted to seek new counsel, and defendant

replied that during the previous 18 months, he had been to his attorneys’ office only once and

claimed that they had rarely communicated with him, including in the lead up to trial. The trial

court did not believe that defendant was being honest, either with the court or his attorneys, and

found that defendant’s explanation was not credible given the timing of the request and defendant’s

statement that he was considering proceeding with a real estate attorney. The trial court noted that

defendant could have sought new counsel or complained about current counsel to the court at any

time during the previous five years but said nothing until the week before trial. The trial court

concluded that the request was an attempt to delay the administration of justice. However, the trial

court stated that if defendant obtained new counsel who was prepared to proceed to trial on April

24, 2023, defendant could substitute counsel.

-3- No. 1-23-1675

¶7 The following day, the trial court held another hearing. Attorney Harkins appeared for

defendant and Attorneys Brett Appleman and Tamara Walker were present via video. Attorneys

Appleman and Walker requested a continuance and told the court that while they were ready to

proceed with the case, they would not be ready for trial on the scheduled jury trial date. Attorney

Harkins suggested that the trial court grant Attorneys Appleman and Walker 60 days to prepare

for trial. The trial court was concerned that if the trial date was reset, defendant would, near the

end of the 60 days, decide that he did not like new counsel and again want new counsel.

¶8 The following day, April 21, 2023, the trial court denied Attorney Harkins’ motion to

withdraw. Attorney Harkins was present in court and Attorneys Appleman and Walker were again

present via video. The trial court reviewed the history of the case, including the several times that

the trial date was reset. The court noted that from 2017 until April 17, 2023, defendant had no

problem with his attorneys’ representation and never complained about his attorneys being

unprepared or not communicating with him. The court also noted other problems with rescheduling

the trial, namely that the court’s calendar was full for months with other pending cases and a critical

prosecution witness, who was overseas, close to retirement, and would likely become unavailable.

The court ultimately found that defendant’s attempt to switch attorneys was a delay tactic and

denied the motion to withdraw. The trial court confirmed that it would address pretrial matters in

the morning on April 24, 2023, and begin jury selection that afternoon. Attorneys Appelman and

Walker did not file appearances on behalf of defendant.

¶9 Attorney Harkins subsequently represented defendant at the pretrial proceedings and at

trial. The jury returned verdicts for theft over $100,000; identity theft over $100,000; identity theft

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

Related

People v. Curry
2013 IL App (4th) 120724 (Appellate Court of Illinois, 2013)
People v. Montgomery
2023 IL App (3d) 200389 (Appellate Court of Illinois, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
2025 IL App (1st) 231675-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-garrett-illappct-2025.