People v. Lomax

2024 IL App (5th) 220566-U
CourtAppellate Court of Illinois
DecidedJanuary 29, 2024
Docket5-22-0566
StatusUnpublished

This text of 2024 IL App (5th) 220566-U (People v. Lomax) 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. Lomax, 2024 IL App (5th) 220566-U (Ill. Ct. App. 2024).

Opinion

2024 IL App (5th) 220566-U NOTICE NOTICE Decision filed 01/29/24. The This order was filed under text of this decision may be NO. 5-22-0566 Supreme Court Rule 23 and is changed or corrected prior to not precedent except in the the filing of a Petition for IN THE limited circumstances allowed Rehearing or the disposition of under Rule 23(e)(1). the same. APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Jefferson County. ) v. ) No. 18-CF-399 ) JAMES J. LOMAX, ) Honorable ) Jerry E. Crisel, Defendant-Appellant. ) Judge, presiding. ______________________________________________________________________________

JUSTICE McHANEY delivered the judgment of the court. Justices Moore and Barberis concurred in the judgment.

ORDER

¶1 Held: No per se conflict of interest existed where plea counsel never assumed the status of an attorney for a prosecution witness. The trial court did not abuse its discretion in denying the defendant’s motion to withdraw his guilty plea where the trial court substantially complied with Rule 402 admonishments at the plea hearing.

¶2 The defendant, James J. Lomax, pled guilty to one count of unlawful possession of a

weapon by a felon (720 ILCS 5/24-1.1(a) (West 2016)) in a partially negotiated plea agreement

that included an agreed sentencing cap and the dismissal of an additional charge. Shortly after the

plea hearing, appointed plea counsel notified the trial court that he had become aware after the

plea hearing that he had a per se conflict of interest. The trial court appointed a new attorney to

represent the defendant going forward but did not inquire as to the nature of the conflict or when

it arose. The defendant later filed a motion to withdraw his guilty plea, arguing that plea counsel

1 provided ineffective assistance and that the trial court failed to substantially comply with the

requirements of Illinois Supreme Court Rule 402 (eff. July 1, 2012). The trial court denied his

motion, and the defendant filed an appeal.

¶3 On direct appeal, the defendant argued that (1) his guilty plea was not knowing and

voluntary because the trial court did not substantially comply with Rule 402 when admonishing

him at the plea hearing and (2) because the record did not establish whether the defendant received

conflict-free representation during the plea proceedings, the cause should be remanded to allow

the trial court to make this crucial finding. Because we agreed with the defendant’s second

contention, we remanded the matter to the trial court to allow it to make that finding but elected

not to address the defendant’s argument concerning the trial court’s admonishments. See People

v. Lomax, 2022 IL App (5th) 190407-U.

¶4 On remand, an evidentiary hearing was held. The trial court determined that plea counsel

did, in fact, have a per se conflict of interest, but that at the time of the guilty plea hearing, plea

counsel was not aware of it. Plea counsel did not become aware of the per se conflict until after

the guilty plea hearing, but before the defendant’s sentencing hearing. The trial court, reasoning

that because plea counsel was unaware of the per se conflict there could be no adverse impact to

the defendant requiring automatic reversal, denied the defendant’s motion to withdraw his guilty

plea. The defendant filed a timely appeal. For the reasons that follow, we affirm.

¶5 I. Background

¶6 Substantial portions of the factual background were originally set forth in People v. Lomax,

2022 IL App (5th) 190407-U. Therefore, we will cite only those facts necessary to this disposition.

The defendant was indicted on one count of unlawful possession of a weapon by a felon (720 ILCS

5/24-1.1(a) (West 2016)) and one count of possession of a stolen firearm (id. § 24-3.8). He pled

2 guilty to the charge of unlawful possession of a weapon by a felon in a partially negotiated plea

agreement, pursuant to which the State dismissed the second charge and agreed to a six-year

sentencing cap, which would be binding on the trial court.

¶7 At the November 20, 2018, plea hearing, the trial court admonished the defendant

concerning the rights he would give up by pleading guilty. Specifically, the trial court told the

defendant that he had the right to be proven guilty beyond a reasonable doubt, the right to a jury

trial, the right to be present at his trial, the right to confront and cross-examine witnesses against

him, the right to present witnesses and other evidence in his defense, the right to remain silent, and

the right to a speedy trial. The trial court advised the defendant that by pleading guilty he was

waiving all of these rights, but it did not specifically advise the defendant that he had the right to

plead not guilty. The defendant indicated that he understood these rights.

¶8 The trial court next admonished the defendant concerning the nature of the charge and the

sentencing range for the offense. The trial court explained that the possible sentencing range for

unlawful possession of a weapon by a felon was 2 to 10 years (see id. § 24-1.1(e)). However, the

trial court did not tell the defendant that he would also serve a one-year period of mandatory

supervised release (MSR) and did not ask the defendant whether he understood the sentencing

range as explained.

¶9 After the State presented a factual basis, the prosecutor described the plea agreement. When

the trial court asked the defendant if that was his understanding of the agreement, the defendant

responded in the affirmative. The trial court then asked the defendant whether anyone had

promised him anything in exchange for his plea and whether anyone had threatened or coerced

him. In response to both questions, he replied, “No.”

3 ¶ 10 The defendant’s next court appearance was a status hearing on December 5, 2018. Plea

counsel, Phillip Butler, stated as follows: “Your Honor, in this case I’ve had a per se conflict come

up that I’ve become aware of since his open plea. I did explain that to [the defendant] and his need

for other representation.” The trial court appointed a new attorney to represent the defendant, but

did not inquire into either the nature of the conflict or when it arose.

¶ 11 On March 28, 2019, the defendant’s second attorney was allowed to withdraw as counsel

due to reassignment within the public defender’s office. On April 17, 2019, the trial court

appointed attorney Matthew Vaughn to represent the defendant.

¶ 12 On July 1, 2019, Vaughn filed on behalf of the defendant a motion to withdraw his guilty

plea. He argued that the defendant had received ineffective assistance of counsel during the guilty

plea proceedings and that the trial court failed to substantially comply with the requirements of

Rule 402 in admonishing the defendant at the plea hearing.

¶ 13 The trial court determined that the defendant’s motion to withdraw his plea was premature

and declined to rule on it until after sentencing. At the end of the July 19, 2019, sentencing hearing,

the trial court sentenced the defendant to five years in prison to be followed by one year of MSR.

¶ 14 On August 26, 2019, the trial court held a hearing on the defendant’s motion to withdraw

his plea.

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Bluebook (online)
2024 IL App (5th) 220566-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-lomax-illappct-2024.