People v. Hart

2021 IL App (2d) 180845-U
CourtAppellate Court of Illinois
DecidedMarch 30, 2021
Docket2-18-0845
StatusUnpublished

This text of 2021 IL App (2d) 180845-U (People v. Hart) 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. Hart, 2021 IL App (2d) 180845-U (Ill. Ct. App. 2021).

Opinion

2021 IL App (2d) 180845-U No. 2-18-0845 Order filed March 30, 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)(l). ______________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

SECOND DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE ) Appeal from the Circuit Court OF ILLINOIS, ) of Jo Daviess County. ) Plaintiff-Appellee, ) ) v. ) No. 17-CF-37 ) WILLIAM A. HART, ) Honorable ) William A. Kelly, Defendant-Appellant. ) Judge, Presiding. ______________________________________________________________________________

JUSTICE HUTCHINSON delivered the judgment of the court. Justices Schostok and Hudson concurred in the judgment.

ORDER

¶1 Held: Summary dismissal of defendant’s postconviction petition was improper where the petition stated the gist of a claim that defendant’s counsel was ineffective for failing to follow defendant’s directive to perfect an appeal after his guilty plea. Defendant did not need to allege what issues he would have raised in his motion to withdraw the plea or in a subsequent appeal.

¶2 Defendant, William A. Hart, appeals the trial court’s order summarily dismissing his

petition brought under the Postconviction Hearing Act (Act) (725 ILCS 5/122-1 et seq. (West

2018)). He contends that he stated the gist of a meritorious claim that his attorney was ineffective

for failing to perfect an appeal. We reverse and remand. 2021 IL App (2d) 180845-U

¶3 I. BACKGROUND

¶4 In 2017, defendant entered a fully negotiated guilty plea to two counts of aggravated

criminal sexual assault (720 ILCS 5/11-1.30(a)(2), (a)(8) (West 2016)). Per the agreement, the

trial court sentenced him to consecutive terms of 15- and 21-years’ imprisonment. The State

dismissed three additional charges.

¶5 The factual basis showed that defendant approached a convenience store clerk. At

gunpoint, he forced her to drive to his home, where he sexually assaulted her. When the police

apprehended defendant a short time later, they found in his home items connected to the assault,

including the gun and the victim’s cellphone.

¶6 On October 15, 2018, defendant filed a postconviction petition. The petition raised several

claims: (1) counsel coerced defendant into pleading guilty; (2) counsel did not investigate a

defense of consensual sex; (3) counsel had a conflict of interest in that he was a friend of the

victim’s family; (4) defendant did not know that the term of mandatory supervised release could

be for life; and (5) counsel reneged on certain promises, including that charges would be dropped

against a “co-defendant.”

¶7 Defendant also alleged that he “told his trial counsel to appeal his sentence and to file a

motion to withdrawl [sic] his plea on the day of sentencing. Trial counsel did not do any of that.”

Defendant further alleged that his attorney negotiated a plea agreement with the prosecutor.

However, “after the defendant plead guilty the terms of the agreement were changed.” Defendant

asked that he be allowed to withdraw his guilty plea “[b]ecause of the ineffectiveness of counsel

and other constitutional violations.”

-2- 2021 IL App (2d) 180845-U

¶8 In an accompanying affidavit, defendant averred that he had a sixth-grade education, had

mental health problems, and took medications that affected his memory and attention span.

Defendant swore that the facts in the petition were true.

¶9 The trial court summarily dismissed the petition. Defendant timely appeals.

¶ 10 II. ANALYSIS

¶ 11 Defendant contends that his petition stated the gist of a claim that his counsel was

ineffective for ignoring defendant’s request to perfect an appeal. He does not argue the merits of

the petition’s other claims.

¶ 12 The Act provides a procedural mechanism for a criminal defendant to assert that he was

deprived of a constitutional right during the proceedings resulting in his conviction. People v.

Edwards, 197 Ill. 2d 239, 244 (2001). A ruling on the sufficiency of the allegations is a legal one

and, therefore, our review is de novo. People v. Coleman, 183 Ill. 2d 366, 378 (1998).

¶ 13 Within 90 days of its filing, the trial court may summarily dismiss a petition if it finds that

the petition is frivolous or patently without merit. 725 ILCS 5/122-2.1(a)(2) (West 2016). A

petition is frivolous or patently without merit only if its allegations, taken as true and construed

liberally, fail to present the “ ‘gist of a constitutional claim.’ ” Edwards, 197 Ill. 2d at 244 (quoting

People v. Gaultney, 174 Ill. 2d 410, 418 (1996)). The “ ‘gist’ ” standard is a “ ‘low threshold.’ ”

Id. (quoting Gaultney, 174 Ill. 2d at 418). To set forth the “ ‘gist’ ” of a constitutional claim, the

petition “ ‘need only present a limited amount of detail’ ” and hence need not set forth the claim

in its entirety. Id. (quoting Gaultney, 174 Ill. 2d at 418.

¶ 14 A petition is frivolous or patently without merit only “ ‘if the petition has no arguable basis

either in law or in fact’ ” in that it relies on “ ‘an indisputably meritless legal theory or a fanciful

factual allegation.’ ” People v. Allen, 2015 IL 113135, ¶ 25 (quoting People v. Hodges, 234 Ill.

-3- 2021 IL App (2d) 180845-U

2d 1, 16-17 (2009)). Meritless legal theories include ones completely contradicted by the record,

while fanciful factual allegations may be “ ‘fantastic or delusional.’ ” Id. (quoting Hodges, 234

Ill. 2d at 17)).

¶ 15 In Edwards, the supreme court reversed a first-stage dismissal where the defendant’s

petition alleged that defense counsel was ineffective for ignoring the defendant’s directive to

perfect an appeal. Edwards, 197 Ill. 2d at 257-58. The dismissal was improper even though the

defendant had pleaded guilty and did not identify in his petition a specific issue he wished to raise.

Edwards, 197 Ill. 2d at 257.

¶ 16 In People v. Rivera, 342 Ill. App. 3d 547, 549 (2003), we asserted that, for purposes of

first-stage postconviction review, a defendant whose lawyer fails to perfect an appeal does not

have to show prejudice beyond the fact that he lost his right to appeal. We followed Edwards in

holding that the trial court erred in summarily dismissing the defendant’s petition alleging

ineffectiveness where the defendant pleaded guilty and his lawyer did not take the necessary steps

to perfect an appeal. Id. at 550-51. We so held even though the defendant’s petition did not specify

an issue he could have raised in his hypothetical appeal, and even though the defendant did not

clearly allege that he even asked his lawyer to appeal. Id.

¶ 17 This case is virtually indistinguishable from Rivera except that here defendant plainly

alleged that he directed his lawyer to perfect an appeal, including filing a motion to withdraw the

plea.

¶ 18 The State insists that Edwards, rather than Rivera, controls this case because here, as in

Edwards, defendant did not file a postplea motion and therefore could not perfect an appeal. See

Edwards, 197 Ill. 2d at 242. The distinction is immaterial, as defendant alleged that he “told his

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Related

People v. Rivera
795 N.E.2d 1016 (Appellate Court of Illinois, 2003)
People v. Coleman
701 N.E.2d 1063 (Illinois Supreme Court, 1998)
People v. Rivera
763 N.E.2d 306 (Illinois Supreme Court, 2001)
People v. Gaultney
675 N.E.2d 102 (Illinois Supreme Court, 1996)
People v. Edwards
757 N.E.2d 442 (Illinois Supreme Court, 2001)
People v. Allen
2015 IL 113135 (Illinois Supreme Court, 2015)

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2021 IL App (2d) 180845-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-hart-illappct-2021.