People v. Hogan

2020 IL App (4th) 180189-U
CourtAppellate Court of Illinois
DecidedMarch 23, 2020
Docket4-18-0189
StatusUnpublished

This text of 2020 IL App (4th) 180189-U (People v. Hogan) 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. Hogan, 2020 IL App (4th) 180189-U (Ill. Ct. App. 2020).

Opinion

NOTICE 2020 IL App (4th) 180189-U FILED This order was filed under Supreme March 23, 2020 Court Rule 23 and may not be cited as precedent by any party except in Carla Bender NO. 4-18-0189 4th District Appellate the limited circumstances allowed under Rule 23(e)(1). Court, IL IN THE APPELLATE COURT

OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) Livingston County MICHAEL HOGAN, ) No. 10CF189 Defendant-Appellant. ) ) Honorable ) Jennifer Hartmann ) Bauknecht, ) Judge Presiding.

JUSTICE HARRIS delivered the judgment of the court. Justices Turner and Cavanagh concurred in the judgment.

ORDER ¶1 Held: We grant the Office of the State Appellate Defender’s motion to withdraw as appellate counsel and dismiss defendant’s appeal as we lack jurisdiction to consider defendant’s claim for additional sentence credit.

¶2 Defendant, Michael Hogan, appeals from the trial court’s order striking his pro se

motion for an order nunc pro tunc as untimely filed. On appeal, the Office of the State Appellate

Defender (OSAD) was appointed to represent defendant. OSAD has filed a motion to withdraw

as appellate counsel, alleging there are no meritorious issues for review. We grant OSAD’s

motion and dismiss defendant’s appeal for lack of jurisdiction.

¶3 I. BACKGROUND ¶4 In July 2010, defendant’s landlord entered defendant’s residence and observed

what he believed to be cannabis plants throughout the home. After the execution of a search

warrant of the premises, police seized between 2000 grams and 5000 grams of cannabis. The

State charged defendant with unlawful production of cannabis, a Class 2 felony (count I) (720

ILCS 550/8(d) (West 2010)), unlawful manufacture of cannabis, a Class 1 felony (count II) (720

ILCS 550/(5)(f) (West 2010)), and possession of a controlled substance, a Class 4 felony (count

III) (720 ILCS 570/402(c) (West 2010)).

¶5 On January 6, 2011, defendant was arrested in El Paso County, Colorado and

subsequently released on January 16, 2011. On March 10, 2011, defendant was arrested in Butte

County, California and transported to the Livingston County jail via extradition on April 14,

2011.

¶6 In February 2012, defendant pleaded guilty to counts II and III in exchange for

the State’s dismissal of count I.

¶7 In April 2012, the trial court sentenced defendant to concurrent terms of 15 years’

imprisonment for count II and 3 years’ imprisonment for count III. The court awarded defendant

sentencing credit of 352 days for time served from April 14, 2011, to March 30, 2012, after

being advised defendant “was released to the Department of Corrections on the 30th of March,

2012, for the violation of parole in [another] case.”

¶8 In May 2012, defendant filed motions to (1) reconsider sentence and (2) withdraw

his guilty plea and vacate judgment, which the trial court later denied. Defendant appealed. On

appeal, defendant argued his 15-year sentence was excessive and that he was entitled to

additional sentencing credit for time spent in custody in Colorado from January 6, 2011, to

January 16, 2011, and again in California from March 10, 2011, to April 14, 2011. This court

-2- affirmed defendant’s 15-year sentence, but we remanded for the proper award of sentencing

credit, concluding defendant was entitled to an additional 47 days of sentencing credit because

defendant was incarcerated in those other states as a result of the charges in the present case. See

People v. Hogan, 2013 IL App (4th) 120684-U, ¶ 1.

¶9 On January 24, 2014, the trial court amended defendant’s written sentencing

judgment specifying defendant was entitled to receive additional credit for time served in

custody from January 6, 2011, to January 16, 2011, and March 10, 2011, to April 13, 2011.

¶ 10 In August 2014, defendant pro se filed a postconviction petition pursuant to the

Post-Conviction Hearing Act (725 ILCS 5/122 et seq. (West 2014)), arguing he was denied the

effective assistance of both his trial and appellate counsel. In October 2014, the trial court

dismissed defendant’s postconviction petition, concluding it was “based on fanciful factual

allegations that are baseless and unsupported by the record.” Defendant appealed, and in March

2017, this court affirmed the trial court’s dismissal of defendant’s postconviction petition. See

People v. Hogan, 2017 IL App (4th) 140986-U, ¶ 1.

¶ 11 On January 16, 2018, defendant filed a motion for an order nunc pro tunc, arguing

his amended sentencing judgment failed to reflect the specific time he spent in custody prior to

being sentenced. Defendant alleged, “[a]s there is some confusion as to the days I’m credited,

could the court reflect on my mittimus, the credit of: 3-10-11 to present, as well as 1-6-11 to 1-

16-11.” Defendant attached to the motion his amended sentencing judgment which gave him

credit “from 1-6-11 to 1-16-11,” “3-10-11 to 4-13-11,” and “4-14-11 to 3-30-12.” In a docket

entry dated January 23, 2018, the trial court struck defendant’s motion, finding it had no

jurisdiction to address the untimely filed motion.

-3- ¶ 12 In March 2018, this court granted defendant leave to file a late notice of appeal

and OSAD was appointed to represent defendant on appeal.

¶ 13 In August 2019, OSAD filed a motion to withdraw as appellate counsel and

attached a memorandum of law. Additionally, this court granted defendant leave to file a

response to OSAD’s motion on or before October 2, 2019, which he did not do.

¶ 14 II. ANALYSIS

¶ 15 OSAD first contends no meritorious argument can be made whether defendant

may seek additional sentencing credit through his motion for an order nunc pro tunc. OSAD

also asserts near the end of its memorandum of law that this court lacks jurisdiction to consider

defendant’s claim for additional sentence credit.

¶ 16 “Normally, the authority of a trial court to alter a sentence terminates after 30

days” following the entry of a final judgment. People v. Flowers, 208 Ill. 2d 291, 303, 802

N.E.2d 1174, 1181 (2003). “The only continuing power the circuit court possess[es] over the

case [is] limited to enforcement of the judgment or correction of clerical errors or matters of

form so that the record conform[s] to the judgment actually rendered.” Id. at 306-07. Clerical

errors are corrected with a nunc pro tunc order. Peraino v. County of Winnebago, 2018 IL App

(2d) 170368, ¶ 16, 101 N.E.3d 780. The purpose of a nunc pro tunc order is to incorporate “into

the record something which was actually previously done by the court but inadvertently omitted

by clerical error” and not “for supplying omitted judicial action, or correcting judicial errors

under the pretense of correcting clerical errors.” People v. Melchor, 226 Ill. 2d 24, 32-33, 871

N.E.2d 32, 36 (2007). “Where the trial court lacks jurisdiction, so do we.” People v. Blancas,

2019 IL App (1st) 171127, 132 N.E.3d 879.

-4- ¶ 17 Critical to our inquiry is whether defendant’s motion for an order nunc pro tunc

sought the exercise of the trial court’s continuous jurisdiction to correct clerical errors or instead

amounted to an untimely request to modify the sentencing judgment. The amended sentencing

judgment credited defendant for time served in custody “from 1-6-11 to 1-16-11,” “3-10-11 to 4-

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Related

People v. Woznick
568 N.E.2d 425 (Appellate Court of Illinois, 1991)
People v. Flowers
802 N.E.2d 1174 (Illinois Supreme Court, 2004)
People v. Melchor
871 N.E.2d 32 (Illinois Supreme Court, 2007)
People v. Coleman
2017 IL App (4th) 160770 (Appellate Court of Illinois, 2017)
People v. Coleman
2017 IL App (4th) 160770 (Appellate Court of Illinois, 2018)
Peraino v. County of Winnebago
2018 IL App (2d) 170368 (Appellate Court of Illinois, 2018)
People v. Blancas
2019 IL App (1st) 171127 (Appellate Court of Illinois, 2019)

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Bluebook (online)
2020 IL App (4th) 180189-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-hogan-illappct-2020.