People v. Henderson

Appellate Court of Illinois·Decided July 1, 2026·No. 2-25-0419·Unpublished

Opinion

2026 IL App (2d) 250419-U No. 2-25-0419

Order filed July 1, 2026

NOTICE: This order was filed under Illinois Supreme Court Rule 23(b) and is not precedential except in the limited circumstances allowed under Rule 23(e)(1).

IN THE

APPELLATE COURT OF ILLINOIS SECOND DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff-Appellee, v.

MARIO H. HENDERSON, Defendant-Appellant

Appeal from the Circuit Court of McHenry County.

Honorable Mark R. Gerhardt, Judge, Presiding.

No. 22-CF-171

PRESIDING JUSTICE KENNEDY delivered the judgment of the court.

Justices Jorgensen and Birkett concurred in the judgment.

ORDER

¶1 Held: Because defendant failed to comply with Illinois Supreme Court Rule 604(d) (eff.

Apr. 15, 2024), we dismiss the appeal.

¶2 Defendant, Mario H. Henderson, entered an open plea of guilty to one count of domestic battery (subsequent offense) (720 ILCS 5/12-3.2(a)(1) (West 2020)), a Class 4 felony (id. § 12- 3.2(b)), in exchange for the dismissal of several additional charges, and was sentenced to two years and six months in prison. Defendant did not file a postplea motion. We granted defendant leave to file a late notice of appeal. On appeal, defendant contends that, although the trial court admonished defendant in accordance with the language of Illinois Supreme Court Rule 605(b) (eff. Apr. 15,

2024) 1, the admonitions were “deficient” because defendant told the court that he did not understand them. According to defendant, his lack of understanding should excuse his failure to file a postplea motion as required under Illinois Supreme Court Rule 604(d) (eff. Apr. 15, 2024). Defendant also maintains that, under the circumstances, the court had an affirmative duty to inquire whether new counsel be appointed. For the reasons that follow, we dismiss the appeal.

¶3 I. BACKGROUND

¶4 On March 17, 2022, defendant was indicted on seven counts of domestic battery (720 ILCS 5/12-3.2(a)(1), (a)(2) (West 2020)) (counts I through VII) and one count of interfering with the reporting of domestic violence (id. § 12-3.5(a)) (count VIII), stemming from an incident that occurred on November 13, 2021. The Office of the Public Defender was initially appointed to represent defendant. However, on November 30, 2023, the trial court discharged the public defender after private counsel—Philip Nathe—filed an appearance on behalf of defendant.

¶5 On March 17, 2025, while represented by Nathe, defendant entered an open plea to one count of domestic battery (subsequent offense) (id. § 12-3.2(a)(1)), a Class 4 felony (id. § 12- 3.2(b)) (count I), in exchange for the dismissal of the remaining charges. The terms of defendant’s sentence were not negotiated. Prior to accepting defendant’s plea, the trial court held a colloquy with defendant pursuant to Illinois Supreme Court Rule 402 (eff. July 1, 2012). During the colloquy, defendant agreed that he wanted to waive his right to a jury trial or bench trial. He agreed that he had discussed this with counsel, understood the waiver form that he signed, and had no questions about the form. The court next advised defendant that the minimum penalty for the

1 Illinois Supreme Court Rule 605 was amended on September 24, 2025, effective January 1, 2026.

See Ill. S. Ct. R. 605 (eff. Jan. 1, 2026). We cite to the version of the rule in effect at the time of the admonishments.

offense was probation or conditional discharge, with 72 hours imprisonment, and that, if the State showed that this was a second or subsequent offense, the maximum penalty was one to three years in prison, with the possibility of an extended-term sentence of up to six years, subject to four years’ mandatory supervised release (MSR). Defendant stated that he understood. The court advised defendant that there was “no definitive sentence at this time” and that, after a sentencing hearing, defendant could be sentenced anywhere between the minimum and maximum sentences. Defendant agreed that he understood. Defendant also indicated that he understood the potential future consequences of the plea as explained by the court. Finally, the court asked defendant whether anyone “forced, threatened, or coerced” him to plead guilty, and defendant replied, “No, sir.” The court also asked defendant, “Other than what we’ve just spoken about, has anyone promised you anything in exchange for doing so,” and defendant replied, “No, sir.” The court found that defendant knowingly, willfully, and voluntarily pleaded guilty.

¶6 The State presented the factual basis for the plea. The State indicated that, if the matter proceeded to trial, the State would prove beyond a reasonable doubt that, on November 13, 2021, defendant bit the victim—a family or household member of defendant—on the abdomen, causing her bodily harm. The State would also prove that defendant had previously been convicted of violating an order of protection in Cook County. Defendant stipulated to the factual basis and its sufficiency. The court accepted the stipulation and found that there was a sufficient factual basis for the plea. Thereafter, court found defendant guilty of count I and dismissed the remaining charges. The matter was continued for the preparation of a presentence investigation report (PSI) and a sentencing hearing.

¶7 The sentencing hearing took place on June 13, 2025. At the outset, after accepting certain corrections to the PSI, the trial court confirmed the potential sentences with counsel and defendant.

Defendant indicated that he understood. The State argued in aggravation that (1) defendant’s conduct caused or threatened serious harm, (2) defendant had a history of prior delinquency for criminal activity, and (3) the sentence was necessary to deter others from committing the same crime. The State also admitted into evidence (1) a certified copy of defendant’s prior conviction of violating an order of protection, a Class 4 felony, and (2) several photographs of the victim taken by a police officer on the scene. The State asked for an extended-term prison sentence. The State emphasized that the incident at issue was a “a very violent attack.” The State also emphasized defendant’s criminal history dating back to 1997, noting that it was “replete with a history of violence,” and included two convictions of violating an order of protection, a prior domestic battery conviction, multiple battery charges, and crimes of dishonesty.

¶8 Defense counsel asked for probation. In mitigation, counsel claimed that defendant suffered from mental and physical health issues that would be endangered if he were imprisoned. Counsel noted that defendant suffered a work-related injury in April 2023. Counsel noted that the PSI reflects “a history of mental health concerns from PTSD to depression to traumatic brain injury. All of those concerns he’s dealt with for some time.” Regarding defendant’s criminal background, counsel argued that “really nothing has occurred with the exception of the instant offenses since the year 2015” and that “[defendant has] been rebuilding his life for ten years seeking counseling, undergoing treatment, remaining employed, and doing what it takes to raise his daughter, support his daughter, and live a crime-free life[.]” . Counsel also noted that defendant pleaded guilty and thus accepted responsibility for the matter.

¶9 In allocution, defendant stated:

“I’m sorry this happened. I’ve really never been out here before. I shouldn’t have probably been out here. I’m sorry I put myself in the position to get myself in trouble again after all the stuff that I’ve been through in my life trying to stay out of trouble.

I don’t know. I just was in a bad position. It shouldn’t have happened. It would never happen again. I mean, I was homeless at the time. I met this girl online. I just should have never been out here, and that incident should have never happened. And I apologize for that.”

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