People v. Hood

2025 IL App (4th) 231257-U
CourtAppellate Court of Illinois
DecidedAugust 4, 2025
Docket4-23-1257
StatusUnpublished

This text of 2025 IL App (4th) 231257-U (People v. Hood) 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. Hood, 2025 IL App (4th) 231257-U (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (4th) 231257-U This Order was filed under FILED Supreme Court Rule 23 and is August 4, 2025 NO. 4-23-1257 not precedent except in the Carla Bender limited circumstances allowed 4th District Appellate under Rule 23(e)(1). IN THE APPELLATE COURT Court, IL

OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) Adams County RICHARD L. HOOD, ) No. 18CF148 Defendant-Appellant. ) ) Honorable ) Zachary P. Boren, ) Judge Presiding.

JUSTICE STEIGMANN delivered the judgment of the court. Justices Knecht and DeArmond concurred in the judgment.

ORDER

¶1 Held: The appellate court affirmed, holding (1) defendant’s successive postconviction petition could not be deemed his initial postconviction petition because there were no deficiencies in the proceedings on the initial petition and (2) alternatively, the trial court properly denied defendant’s motion to file a successive postconviction petition because he failed to satisfy the cause-and-prejudice test.

¶2 Following a jury trial, defendant, Richard L. Hood, was convicted of three counts

of criminal sexual assault (720 ILCS 5/11-1.20(a)(1) (West 2018)) and one count of unlawful

restraint (id. § 10-3), and he was subsequently sentenced to an aggregate term of 30 years in

prison. This court affirmed defendant’s convictions and sentences on direct appeal. See People v.

Hood, 2022 IL App (4th) 200260, ¶ 141.

¶3 While defendant’s direct appeal was pending, he pro se filed a postconviction

petition pursuant to the Post-Conviction Hearing Act (Act) (725 ILCS 5/122-1 et seq. (West

2020)). The trial court summarily dismissed his petition, finding that the issues he raised were (1) not new, (2) going to be addressed on direct appeal, or (3) frivolous or patently without merit.

Defendant appealed. This court allowed defendant to proceed pro se, as he requested, and we

ultimately dismissed the appeal for want of prosecution after defendant failed to file a brief.

¶4 Thereafter, defendant moved to file a successive postconviction petition. See 725

ILCS 5/ 122-1(f) (West 2022). The trial court denied the motion.

¶5 Defendant appeals that denial, arguing (1) his successive postconviction petition

must be treated as his first because the proceedings on the initial petition were deficient and

(2) alternatively, the trial court erred in denying him leave to file a successive petition. We

affirm.

¶6 I. BACKGROUND

¶7 The facts of this case are well known to the parties and this court. Accordingly,

we recite here only those facts necessary to resolve the issues defendant raises in this appeal.

¶8 A. The Conviction and Filing of the Direct Appeal

¶9 In February 2018, the State charged defendant with criminal sexual assault and

unlawful restraint after he lured B.L.M. to his home under the guise that she could do her laundry

at his house, and he would pay her to clean his home. While in the house, defendant kept B.L.M.

in his bedroom for several hours and repeatedly assaulted her.

¶ 10 In April 2019, a jury found defendant guilty of all counts, and the trial court

subsequently sentenced defendant to a total of 30 years in prison.

¶ 11 In June 2020, after defendant was sentenced, he filed a notice of appeal, and

appellate counsel was appointed to represent him.

¶ 12 In November 2020, appellate counsel moved to withdraw and asked this court to

allow defendant to proceed pro se. We denied both motions. Defendant moved to reconsider and

-2- appealed to the supreme court via a mandamus action.

¶ 13 In January 2021, we denied defendant’s motion to reconsider, explaining that

“[defendant] has presented no valid reason to believe the Office of the State Appellate Defender

cannot represent his interests adequately.”

¶ 14 B. The Initial Postconviction Petition

¶ 15 In February 2021, while defendant’s direct appeal was pending in this court,

defendant pro se filed his initial postconviction petition. His allegations were handwritten on a

preprinted form. Under the section that asked defendant to specify the constitutional rights he

was denied, he asserted, in total, the following:

“I want to raise all the issues that I raised and tried to raise in all my pre

and post trial motions and the newly discovered issues discovered during [another

case]. I want a different judge to consider [the] petition. Also, see my wife’s

affidavit filed in her case *** and the affidavit from Cameron Coulter I’m mailing

with this.”

Attached to defendant’s petition was Coulter’s affidavit, which was (1) written by defendant,

(2) not notarized, and (3) dated February 4, 2019, two months before defendant’s trial began.

Coulter attested he (1) had provided drugs to defendant in the past, (2) did not provide defendant

with drugs on the day of the incident, and (3) had partied with defendant and women with whom

he and defendant had sex.

¶ 16 Thereafter, defendant filed four supplements to his petition, one on February 22,

2021, two on February 26, 2021, and one on March 9, 2021. In these supplements, defendant

claimed (1) the State engaged in various acts of misconduct; (2) the State withheld from the jury

recordings of phone calls between B.L.M. and her boyfriend, who was in jail; (3) a nurse lied

-3- about bruises on B.L.M.’s neck; (4) “[h]ad there been any bruise, pictures of it would have been

mandated”; (5) a therapist who treated B.L.M. knew about and was prejudiced by another

woman who falsely accused defendant of holding her against her will for hours and beating her;

(6) Betsy Bier, an assistant public defender appointed to represent defendant after trial who was

subsequently dismissed when defendant was allowed to proceed pro se, was ineffective because

she failed to raise “all the relevant and meritorious issues [defendant] raised and tried to raise,”

including that the therapist who treated B.L.M. also treated another woman who accused

defendant of similar offenses; and (7) he was not allowed to see the warrant for his arrest where,

regarding the bond amount, a “5” was written over a “0.” Attached to defendant’s last

supplement was his wife’s affidavit, wherein she attested that (1) she and defendant wanted to

help B.L.M., (2) B.L.M. sexually assaulted defendant, and (3) defendant never harmed B.L.M.

¶ 17 In March 2021, the trial court, which construed defendant’s initial petition and the

supplements as one postconviction petition, summarily dismissed the petition. The court found,

“Defendant’s petition fail[ed] to clearly state the details as to how he believes his constitutional

rights were violated.” After noting defendant “appear[ed]” to focus on a freestanding actual

innocence claim based on newly discovered evidence, the court found that some of the new

evidence was addressed in another case of defendant’s that the State had nol-prossed. Thus, the

evidence was not new. The court also found that the following evidence was not new:

(1) allegations of prosecutorial misconduct, which the court addressed during trial and defendant

raised in a letter to his appellate counsel; (2) the recorded phone calls between B.L.M. and her

boyfriend, which were tendered to defendant during discovery; (3) Coulter’s affidavit, which did

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Bluebook (online)
2025 IL App (4th) 231257-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-hood-illappct-2025.