People v. Muhammad-Ali

2021 IL App (1st) 171721-U
CourtAppellate Court of Illinois
DecidedJanuary 22, 2021
Docket1-17-1721
StatusUnpublished
Cited by1 cases

This text of 2021 IL App (1st) 171721-U (People v. Muhammad-Ali) 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. Muhammad-Ali, 2021 IL App (1st) 171721-U (Ill. Ct. App. 2021).

Opinion

2021 IL App (1st) 171721-U

SIXTH DIVISION January 22, 2021

No. 1-17-1721

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1).

IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Cook County. ) v. ) No. 13 CR 23742 ) SOLOMON MUHAMMAD-ALI, ) Honorable ) Ursula Walowski, Defendant-Appellant. ) Judge Presiding.

PRESIDING JUSTICE MIKVA delivered the judgment of the court. Justices Connors and Oden Johnson concurred in the judgment.

ORDER

¶1 Held: Trial court abused its discretion where it denied defense counsel’s motion for a continuance due to illness.

¶2 The defendant in this case, Solomon Muhammad-Ali, was convicted of aggravated

domestic battery following a jury trial. The trial court sentenced him to three years in prison. On

appeal, Mr. Muhammad-Ali argues that (1) the trial court abused its discretion in denying his

counsel’s motion for a continuance where counsel was suffering from an illness, and that this

prevented him from receiving a fair trial, (2) the State improperly asked the jury to empathize with No. 1-17-1721

the victim to bolster her credibility, and (3) the trial court failed to conduct a proper inquiry

pursuant to People v. Krankel, 102 Ill. 2d 181 (1984), after counsel alleged his own ineffectiveness.

¶3 The State in this case failed, despite being granted three continuances, to file a timely brief

in this matter. On October 2, 2020—seventeen months after Mr. Muhammad-Ali had filed his

opening brief and over nine months after the last date given for the State to respond—this court

granted Mr. Muhammad-Ali’s motion to decide the issues based solely on his opening brief and

the record on appeal.

¶4 For the following reasons, we reverse Mr. Muhammad-Ali’s conviction and remand for a

new trial.

¶5 I. BACKGROUND

¶6 Mr. Muhammad-Ali was charged with aggravated domestic battery following an incident

with his then-girlfriend, Ashley Smith. He was assigned a public defender on January 9, 2014. On

March 24, 2014, private attorney Thomas O’Gara filed an appearance on behalf of Mr.

Muhammad-Ali, and the public defender’s office withdrew from the case. At the request of Mr.

Muhammad-Ali, the court held a conference, pursuant to Illinois Supreme Court Rule 402 (eff.

July 1, 2012), on June 9, 2014, and the case was continued by agreement until June 19 for Mr.

Muhammad-Ali and his family to consider the State’s offer. On June 19, 2014, Mr. O’Gara

withdrew from the case and the public defender’s office again filed an appearance. The parties

continued the case by agreement multiple times in what appears from the record to be the normal

course of discovery.

¶7 Between April 22, 2015, and September 16, 2015, Mr. Muhammad-Ali made several

motions for continuances, while attempting to again obtain new private counsel. During the

September 16 hearing, the trial court told Mr. Muhammad-Ali, “I will give you a 30-day date, and

2 No. 1-17-1721

I will mark it final. If you don’t have a private attorney by then, let [the public defender] know

beforehand. He is working on the case, but we need to move this forward.” Mr. Muhammad-Ali

was unable to obtain a private attorney by the next hearing, and the public defender’s office was

assigned to continue with the case. On November 30, 2015, Mr. Muhammad-Ali filed his answer

to discovery and the case was set for a bench trial on January 26, 2016.

¶8 On January 26, 2016, Mr. Muhammad-Ali again moved for a continuance to obtain private

counsel, which the court granted. On February 8, 2016, the public defender’s office withdrew from

the case, and private attorney Bernard Shelton filed an appearance on behalf of Mr. Muhammad-

Ali. Mr. Shelton moved for continuances during that hearing and again on March 2, 2016, to obtain

discovery materials from Mr. Muhammad-Ali’s former public defender. The parties then

continued the case by agreement until July 25, 2016, when Mr. Muhammad-Ali moved for a

continuance to put together a mitigation packet. The case was continued several more times by

agreement or court order until trial was set for Monday, February 27, 2017.

¶9 On the morning trial was set to begin, Mr. Shelton made an oral motion for a continuance.

He explained to the court that he recently had food poisoning and was still recovering. He stated

his voice was gone and that he was “not in a position to give [Mr. Muhammad-Ali] the jury trial

that he deserves in this matter.” The court responded, “[w]ell, Mr. Shelton, we can pick [the jury]

today, and then you’ll have the rest of the day until tomorrow. And then we could [begin] the trial

[tomorrow]. So all we have to do is get through picking today at least.” Mr. Shelton again stated

that he was “not in a position to give [Mr. Muhammad-Ali] [his] best jury trial selection or perform

a trial tomorrow being that [he was] just coming down from a bad food poisoning.” The court

stated, “the problem is sometimes, you know, we do have to sacrifice” and later noted, “I

understand, Mr. Shelton, your condition, so I’m trying to be as, you know, as reasonable as possible

3 No. 1-17-1721

here to give you a break so that you can proceed to trial. But this is a [2013] case. It’s an old case.”

The parties then proceeded with jury selection. The following day, the trial court was informed

that Mr. Shelton was hospitalized and could not appear in court. The trial court continued the case

until the next day, which was Wednesday, March 1, 2017. Mr. Shelton appeared then and

“resubmit[ted]” his oral motion for a continuance, stating:

“[W]hen we came in on Monday, I advised the Court that I had just been ill and was just

getting over an illness and that I was not healthy. The Court—what the Court said is what

you would do for us is to just allow me just to pick the jury that day and we will go forward

and start the trial the next day. I had no choice. We went forward. *** Late Monday into

Tuesday I became seriously ill where I had to go to the emergency room with extreme

swelling to my face. Upon being seen by medical personnel, I was advised that they

suspected that I had what is called angioedema and *** I was advised that that is something

that can come on and present in a manner of swelling to the face or various body parts

immediately after a serious illness or a bout with someone’s immune system and while

they can’t be certain that’s what it is, I was given medication to deal with the symptoms,

but you can’t prevent that. *** It may pop up over the next few days while your body still

heals from the virus and the virus and/or the food poisoning that I was recovering from.

That was yesterday. Today is Wednesday. I am still not 100 percent *** and to make Mr.

[Muhammad]-Ali who is facing the penalties of a Class 2 felony *** go forward with his

attorney in this condition *** I believe is [a] violation of [his] right to a fair trial.”

The court initially responded by requesting the parties engage in a Rule 402 conference. Mr.

Muhammad-Ali rejected the offer of three years in prison. The court then denied the motion for a

continuance, stating:

4 No. 1-17-1721

“Monday I know that I denied your motion for a continuance. I thought that you did a fin[e]

job. You were prepared in your jury selection.

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Related

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Cite This Page — Counsel Stack

Bluebook (online)
2021 IL App (1st) 171721-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-muhammad-ali-illappct-2021.