People v. Lawson

2025 IL App (4th) 240323-U
CourtAppellate Court of Illinois
DecidedJune 13, 2025
Docket4-24-0323
StatusUnpublished

This text of 2025 IL App (4th) 240323-U (People v. Lawson) 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. Lawson, 2025 IL App (4th) 240323-U (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (4th) 240323-U This Order was filed under FILED Supreme Court Rule 23 and is NO. 4-24-0323 June 13, 2025 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. ) Peoria County ROBERT J. LAWSON, ) No. 11CF800 Defendant-Appellant. ) ) Honorable ) Katherine S. Gorman, ) Judge Presiding.

JUSTICE DOHERTY delivered the judgment of the court. Justices Steigmann and Vancil concurred in the judgment.

ORDER

¶1 Held: Appointed trial counsel should not have been permitted to withdraw prior to the disposition of defendant’s postconviction petition, but the error was harmless because the State conceded the sole meritorious claim and defendant obtained the only relief available on that claim. Additionally, even assuming that defendant did not receive a copy of his attorney’s motion to withdraw, any error is harmless when there was no additional meritorious relief his attorney could pursue.

¶2 Defendant Robert J. Lawson was convicted of two counts of attempted murder (720

ILCS 5/8-4(a), 9-1(a)(1) (West 2010)) and one count of aggravated unlawful use of a weapon

(AUUW) (720 ILCS 5/24-1.6(a)(1) (West 2010)). He was sentenced to 20 years in prison, plus a

25-year firearm enhancement, on each attempted murder charge and 7 years on the AUUW

conviction.

¶3 In 2020, defendant was granted leave to file a successive postconviction petition,

in which he argued that his AUUW conviction should be vacated as unconstitutional and that the court should reconsider his sentencing in light of Miller v. Alabama, 567 U.S. 460 (2012), and the

emerging adult theory. Following the State’s concession that the AUUW conviction was

unconstitutional and should be vacated, the circuit court granted defendant’s counsel’s motion to

withdraw. The court then held a hearing on the State’s motion to dismiss, vacated defendant’s

AUUW conviction, and found that the remaining issue lacked merit.

¶4 Defendant appeals, arguing that (1) he was denied reasonable assistance of counsel

because his attorney was allowed to withdraw when it was undisputed that his successive

postconviction petition contained a viable issue regarding his AUUW conviction and (2) he was

denied procedural due process because his attorney was allowed to withdraw without ensuring that

defendant received a copy of the attorney’s motion to withdraw or had an opportunity to respond

to it. The State concedes that defendant’s counsel should not have been allowed to withdraw but

argues that any error was harmless.

¶5 For the reasons stated below, we affirm.

¶6 I. BACKGROUND

¶7 In 2011, defendant was charged by indictment with four counts of attempted first

degree murder (720 ILCS 5/8-4(a), 9-1(a)(1) (West 2010)), two counts of aggravated battery (720

ILCS 5/12-3.05(e)(1) (West 2010), one count of AUUW (720 ILCS 5/24-1.6(a)(1) (West 2010)),

and two counts of mob action (720 ILCS 5/25-1(a)(1) (West 2010)). The underlying facts of the

case were summarized as follows in defendant’s direct appeal:

“At trial, the evidence indicated that on August 15, 2011, at approximately

1 p.m., defendant rode his bicycle to a convenience store with a passenger on the

back. Defendant got off his bicycle and approached a vehicle parked at the curb in

front of the store. Defendant pulled out a handgun, opened the door to the vehicle,

-2- and fired the handgun into the vehicle at the two front-seat occupants. Defendant

continued to shoot at the vehicle as it drove away from the scene. Both occupants

were shot, but neither were fatally injured. One of the occupants received gunshot

wounds to his leg and arm. The second occupant received a gunshot wound to his

leg, which struck an artery and required the placement of a metal rod inside his leg.

The jury found defendant guilty on all counts, except for the two counts of mob

action.” People v. Lawson, 2013 IL App (3d) 120148-U, ¶ 5.

¶8 At the sentencing hearing in 2012, the trial court considered defendant’s

presentence investigation report (PSI), which prompted the court to have the following colloquy

with defendant:

“THE COURT: Let me ask you this: I read the PSI, as I always do, and they

are very good with our Probation Department in preparing them. How come

everybody is shooting at you?

THE DEFENDANT: I can’t speak for nobody else. I just—

THE COURT: I mean, you’ve been shot once, right?

THE DEFENDANT: Twice.

THE COURT: Twice. And there have been other times when you’ve been

shot at and not hit, right?

THE DEFENDANT: Right.

THE COURT: How come everybody’s shooting at you?

THE DEFENDANT: I guess they just don’t—some people just don’t like

me, and I’m in the same neighborhood. It ain’t like I can get away from ’em. I’m

stuck around the same people that don’t like me. I don’t got no—I can’t just up and

-3- relocate when things happen, so I’m stuck around it.”

¶9 Defendant was sentenced to 20 years’ imprisonment, plus a 25-year firearm

enhancement for each attempted murder conviction, and 7 years’ imprisonment for the AUUW

¶ 10 Defendant moved to reconsider his sentence, and at the hearing on the motion, the

court commented as follows:

“I’ve given a lot of thought to this sentence after the fact, and I can’t help but think

that somehow it’s tied into the fact that [defendant]—I’m talking about this

incident. Somehow Mr.—or I think it’s—I can’t help but think that it’s tied into the

fact that [defendant] had been shot at quite a few times over his life. And I asked

him about that, because I’m concerned that I’m only seeing this part of a bigger

picture. But [defendant] chose not to really answer that question when I asked him,

‘Why is everybody shooting at you?’ And he said, ‘They don’t like me.’ ”

¶ 11 The court denied the motion to reconsider.

¶ 12 A. Direct Appeal

¶ 13 In defendant’s direct appeal of his conviction, he argued that the trial court

considered an improper aggravating factor and further failed to consider mitigating factors in

imposing his sentence; the trial court’s judgment was affirmed. Id. Defendant then filed a petition

for leave to appeal with the Illinois Supreme Court, which was denied. People v. Lawson, No.

118263 (2014).

¶ 14 B. First Postconviction Petition

¶ 15 In 2015, defendant filed his first postconviction petition, arguing a number of errors

and asserting ineffective assistance of both trial and appellate counsel for not raising those issues

-4- on direct appeal. The postconviction petition was denied after the third stage, and on appeal,

defendant’s counsel filed a motion to withdraw pursuant to Anders v. California, 386 U.S. 738

(1967), which was allowed. People v. Lawson, No. 3-18-0460, 8 (2020) (unpublished order under

Illinois Supreme Court Rule 23(e)(1)).

¶ 16 C. Successive Postconviction Petition

¶ 17 In May 2020, defendant filed a motion for leave to file a successive postconviction

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Anders v. California
386 U.S. 738 (Supreme Court, 1967)
People v. Payne
456 N.E.2d 44 (Illinois Supreme Court, 1983)
People v. Aguilar
2013 IL 112116 (Illinois Supreme Court, 2014)
People v. Olsson
2014 IL App (2d) 131217 (Appellate Court of Illinois, 2014)
People v. Kuehner
2015 IL 117695 (Illinois Supreme Court, 2015)
Miller v. Alabama
132 S. Ct. 2455 (Supreme Court, 2012)
People v. Burns
2015 IL 117387 (Illinois Supreme Court, 2016)
People v. Richey
2017 IL App (3d) 150321 (Appellate Court of Illinois, 2017)
People v. Buffer
2019 IL 122327 (Illinois Supreme Court, 2020)
People v. Stoecker
2020 IL 124807 (Illinois Supreme Court, 2020)
People v. McMillen
2021 IL App (1st) 190442 (Appellate Court of Illinois, 2021)
People v. Lopez
497 N.E.2d 859 (Appellate Court of Illinois, 1986)
People v. Pingelton
2022 IL 127680 (Illinois Supreme Court, 2022)
Erickson v. Knox County Wind Farm LLC
2024 IL App (4th) 230726 (Appellate Court of Illinois, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
2025 IL App (4th) 240323-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-lawson-illappct-2025.