People v. Hills

2025 IL App (4th) 241331-U
CourtAppellate Court of Illinois
DecidedOctober 2, 2025
Docket4-24-1331
StatusUnpublished

This text of 2025 IL App (4th) 241331-U (People v. Hills) 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. Hills, 2025 IL App (4th) 241331-U (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (4th) 241331-U FILED This Order was filed under October 2, 2025 Supreme Court Rule 23 and is NO. 4-24-1331 Carla Bender not precedent except in the 4th District Appellate limited circumstances allowed IN THE APPELLATE COURT Court, IL under Rule 23(e)(1).

OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) Adams County JASON L. HILLS, ) No. 18CF450 Defendant-Appellant. ) ) Honorable ) John C. Wooleyhan, ) Judge Presiding.

JUSTICE DeARMOND delivered the judgment of the court. Presiding Justice Harris and Justice Doherty concurred in the judgment.

ORDER

¶1 Held: The trial court’s denial of defendant’s amended postconviction petition after a third-stage evidentiary hearing was not error.

¶2 Defendant, Jason L. Hills, was convicted of two counts of criminal sexual assault

(720 ILCS 5/11-1.20(a)(2) (West 2016)) and sentenced to five years’ imprisonment on each

count, to be served consecutively. He now appeals from the trial court’s denial of his amended

postconviction petition after a third-stage evidentiary hearing, claiming the denial was against

the manifest weight of the evidence. We affirm.

¶3 I. BACKGROUND

¶4 In October 2021, after his conviction was affirmed on direct appeal (see People v.

Hills, 2021 IL App (4th) 200220-U, ¶ 49 (Hills I)), defendant filed a postconviction petition,

claiming he was denied the effective assistance of trial counsel. In particular, defendant alleged counsel rendered ineffective assistance by failing to (1) investigate and adequately cross-

examine a witness regarding the victim’s post-traumatic stress disorder (PTSD), (2) consult,

retain, and call a forensic psychologist to testify at trial, and (3) introduce pharmacological

evidence disputing the victim’s claim she did not recall the sexual assaults from which the

charges arose. The trial court summarily dismissed the petition at the first stage of postconviction

proceedings. Defendant appealed, and this court reversed the trial court’s summary dismissal and

remanded the cause for second-stage postconviction review. People v. Hills, 2023 IL App (4th)

220141-U, ¶ 28 (Hills II).

¶5 Defendant thereafter filed an amended postconviction petition, which included

two new claims. Specifically, defendant alleged trial counsel failed to (1) investigate and present

expert testimony to contradict the victim’s claim she was unconscious after consuming one

tramadol pill and approximately three shots of alcohol and (2) present expert testimony to

contradict the victim’s claim that she suffered bruising because of the sexual assault. The trial

court initially dismissed the amended petition. However, upon defendant’s motion for

reconsideration, the court permitted the amended petition to proceed to a third-stage evidentiary

hearing.

¶6 At the third-stage hearing, Dr. Shiping Bao, a forensic pathologist, testified

regarding the effects of alcohol and tramadol and the age of the bruises. Dr. Tetyana Kostyshyna,

a forensic psychologist, testified regarding whether the State’s expert’s “methodology for

diagnosis of PTSD was proper in this case and met the minimum requirements for forensic and

psychological relations.” Defendant’s trial counsel testified to his trial strategy. After the

hearing, the trial court entered a written order denying the amended petition.

¶7 This appeal followed. We note the facts of the underlying case are fully set forth

-2- in Hills I, and Hills II discusses some of the claims before us. We reference only the relevant

testimony from the third-stage hearing and trial in our analysis below.

¶8 II. ANALYSIS

¶9 On appeal, defendant contends the trial court’s decision to deny postconviction

relief following the third-stage evidentiary hearing was against the manifest weight of the

evidence. Defendant argues the court erred by (1) observing in its denial order that the amount of

evidence presented at trial and in the appellate court’s previous opinion greatly exceeded the

evidence contained in defendant’s petition, (2) finding his expert witnesses were not credible,

and (3) finding he failed to establish either prong necessary for a showing of ineffective

assistance of counsel. Although we review the court’s decision to deny postconviction relief for

manifest error, we apply a hybrid standard of review when asked to consider ineffective

assistance of counsel claims. People v. Phillips, 2017 IL App (4th) 160557, ¶ 55. “[W]e defer to

the trial court’s factual findings and will disturb them only if they are against the manifest weight

of the evidence but review de novo the court’s ultimate determination of whether counsel

rendered ineffective assistance.” Phillips, 2017 IL App (4th) 160557, ¶ 55.

¶ 10 A. Postconviction Proceedings

¶ 11 The Post-Conviction Hearing Act (Act) (725 ILCS 5/122-1 et seq. (West 2022))

“provides a mechanism for criminal defendants to challenge their convictions or sentences based

on a substantial violation of their rights under the federal or state constitutions.” People v.

Morris, 236 Ill. 2d 345, 354 (2010). “Postconviction proceedings are not a continuation of, or an

appeal from, the original case.” People v. Harris, 224 Ill. 2d 115, 124 (2007). Rather, a

proceeding under the Act “is a collateral attack upon the prior conviction and affords only

limited review of constitutional claims not presented at trial.” Harris, 224 Ill. 2d at 124.

-3- ¶ 12 The Act establishes a three stage process for adjudicating a postconviction

petition. People v. English, 2013 IL 112890, ¶ 23. At the third stage, unlike the first two, the

allegations are not taken as true. Instead, “the circuit court serves as the factfinder, determining

witness credibility, deciding the weight to be given testimony and evidence, and resolving any

evidentiary conflicts.” People v. Harris, 2025 IL 130351, ¶ 40. “The [defendant] has the burden

to ultimately prove by a preponderance of the evidence that his constitutional rights were

violated, warranting a new trial.” Harris, 2025 IL 130351, ¶ 40. “Where a trial court’s decision

to deny a postconviction petition after a third-stage evidentiary hearing is based on disputed

issues of fact that requires credibility determinations, we will reverse that decision only if it is

manifestly erroneous.” Phillips, 2017 IL App (4th) 160557, ¶ 55. Manifest error is error that is

“clearly evident, plain, and indisputable.” (Internal quotation marks omitted.) People v.

Coleman, 2013 IL 113307, ¶ 98.

¶ 13 B. The Denial Order’s Language

¶ 14 Defendant’s claims here are based on the trial court’s fact-finding and credibility

determinations. Because the same judge presided over defendant’s trial and third-stage hearing,

we give the trial court the heightened deference it deserves, as it had the opportunity to observe

trial counsel’s conduct during the proceedings below. See People v. Jacobazzi, 398 Ill. App. 3d

890, 912 (2009). “This deferential standard is appropriate because the trial court is in the best

position to observe and weigh the credibility of the witnesses.” Jacobazzi, 398 Ill. App. 3d at

912. As a result, we will give the trial court’s credibility determinations even greater deference

when reviewing the record for manifest error.

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Related

People v. Coleman
2013 IL 113307 (Illinois Supreme Court, 2013)
People v. English
2013 IL 112890 (Illinois Supreme Court, 2013)
People v. Domagala
2013 IL 113688 (Illinois Supreme Court, 2013)
People v. Harris
862 N.E.2d 960 (Illinois Supreme Court, 2007)
People v. Hamilton
838 N.E.2d 160 (Appellate Court of Illinois, 2005)
People v. Morris
925 N.E.2d 1069 (Illinois Supreme Court, 2010)
People v. Perry
864 N.E.2d 196 (Illinois Supreme Court, 2007)
People v. JACOBAZZI
966 N.E.2d 1 (Appellate Court of Illinois, 2010)
People v. Coleman
2015 IL App (4th) 131045 (Appellate Court of Illinois, 2015)
People v. Williams
2017 IL App (1st) 152021 (Appellate Court of Illinois, 2017)
People v. Phillips
2017 IL App (4th) 160557 (Appellate Court of Illinois, 2017)
People v. Elliott
2022 IL App (1st) 192294 (Appellate Court of Illinois, 2022)
People v. Hayes
2022 IL App (4th) 210409 (Appellate Court of Illinois, 2022)
People v. Hills
2023 IL App (4th) 220141-U (Appellate Court of Illinois, 2023)
People v. House
2023 IL App (4th) 220891 (Appellate Court of Illinois, 2023)
People v. Carter
2021 IL App (4th) 180581 (Appellate Court of Illinois, 2021)
People v. Harris
2025 IL 130351 (Illinois Supreme Court, 2025)

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Bluebook (online)
2025 IL App (4th) 241331-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-hills-illappct-2025.