People v. Nowlin

2025 IL App (4th) 230770-U
CourtAppellate Court of Illinois
DecidedJanuary 28, 2025
Docket4-23-0770
StatusUnpublished

This text of 2025 IL App (4th) 230770-U (People v. Nowlin) 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. Nowlin, 2025 IL App (4th) 230770-U (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (4th) 230770-U This Order was filed under FILED Supreme Court Rule 23 and is NO. 4-23-0770 January 28, 2025 not precedent except in the Carla Bender limited circumstances allowed 4th District Appellate IN THE APPELLATE COURT under Rule 23(e)(1). Court, IL OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) McLean County MISOOK NOWLIN, ) No. 11CF800 Defendant-Appellant. ) ) Honorable ) Scott Kording, ) Judge Presiding.

JUSTICE KNECHT delivered the judgment of the court. Justices Steigmann and Cavanagh concurred in the judgment.

ORDER

¶1 Held: As defendant failed to prove she could not meaningfully communicate with the court or counsel, she did not prove she was denied due process or the assistance of counsel in the second and third stages of postconviction proceedings when she was not provided an interpreter.

¶2 In January 2023, the trial court denied the postconviction petition of defendant,

Misook Nowlin, after holding a third-stage evidentiary hearing under section 122-6 of the Post-

Conviction Hearing Act (Act) (725 ILCS 5/122-6 (West 2022)). Defendant appeals, arguing

various claims based on her alleged inability to understand English: (1) she was denied due

process at the hearing, (2) she was constructively denied her statutory right to postconviction

counsel during the second and third stages of proceedings, and (3) counsel provided

unreasonable assistance by not requesting an interpreter. We affirm. ¶3 I. BACKGROUND

¶4 In September 2011, defendant was charged with three counts of the first degree

murder of her mother-in-law (720 ILCS 5/9-1(a)(1), (a)(2) (West 2010)) and one count of

concealment of a homicidal death (720 ILCS 5/9-3.4(a) (West 2010)). On the first day of trial in

December 2012, defendant pleaded guilty to the concealment charge. The jury trial proceeded on

the first degree murder charges.

¶5 A. Trial

¶6 At trial, defendant testified without the aid of an interpreter. We need not provide

a thorough summary of the trial proceedings as, for the most part, those proceedings are

irrelevant to this appeal. It is worth noting, however, defendant provided lengthy testimony in

support of her claim her mother-in-law’s death was the result of self-defense. The transcript from

defendant’s trial contains approximately 70 pages of her testimony. The jury found defendant

guilty of first degree murder. She was sentenced to consecutive prison terms of 50 years for

murder and 5 years for concealment.

¶7 In January 2013, defendant sent two letters to the trial court asserting, in part, she

was denied the effective assistance of trial counsel when counsel denied her request to seek an

interpreter. The following month, the court held a hearing on those allegations pursuant to

People v. Krankel, 102 Ill. 2d 181, 464 N.E.2d 1045 (1984). At that hearing, defendant testified

her daughter told her, “[Y]ou can speak English but you have an accent[ ] and some people don’t

understand.” Because of this, on the first day of trial, defendant asked one of her trial attorneys,

Carla Barnes, for a translator, but Barnes denied her request. When the court asked Barnes and

defendant’s other trial attorney, Brian McEldowney, whether defendant made such a request,

both replied she did not.

-2- ¶8 At the close of the hearing, the trial court found defendant’s claim baseless,

concluding the record demonstrated defendant did not need an interpreter. The court found

counsel’s statements credible and determined the following:

“Never once during this case while it was pending did you

ever indicate to the Court that you needed an interpreter, that is

clear. Throughout the case the Court has had the opportunity to

observe you in court, observe you while you testified in court on a

number of different occasions at different hearings including the

trial. The Court was able to view your videotaped interview with

the police in which you had a conversation wholly in English. The

Court did not note anything in any of those observations that

suggested that you needed an interpreter. The Court had been

informed through evidence at hearings in the case that you had

been in this country for a long time, you had operated a business

here, you had worked as an interpreter translating Korean into

English and English into Korean for a period of time. And in

addition to all of that, the Court also went back, frankly I went

back and I reviewed all of your prior court files in which you had

appeared in County Court in two felony and several misdemeanor

trials. I reviewed the records in all of those cases and noted that

never once was an interpreter requested or used in any of those

cases, including a trial that was held in at least one of those cases, a

bench trial.”

-3- ¶9 B. Direct Appeal

¶ 10 After the Krankel hearing, defendant filed a direct appeal. On appeal, defendant

argued (1) her murder conviction should be reversed, as the trial court allowed a detective who

would testify against defendant to sit at the prosecution’s table during trial, and (2) regarding her

concealment conviction, this court should remand for strict compliance with Illinois Supreme

Court Rule 604(d) (eff. Feb. 6, 2013)). People v. Nowlin, 2015 IL App (4th) 130387-U, ¶ 3. We

affirmed defendant’s murder conviction. Id. As to the concealment conviction, we vacated the

order denying defendant’s motion to reconsider sentence and remanded for the filing of a Rule

604(d) certificate, the opportunity to file a motion to withdraw the guilty plea or a motion to

reconsider sentence, and a new hearing. Id.

¶ 11 On remand, defendant filed a motion to reconsider her sentence. In September

2015, a hearing on the motion to reconsider sentence was held, and the motion was denied. She

appealed, arguing the trial court failed to admonish her the sentence for concealment would run

consecutively to her sentence for murder. People v. Nowlin, 2017 IL App (4th) 150957-U, ¶ 2.

Because defendant did not file a motion to withdraw her guilty plea, we lacked jurisdiction to

consider her claim. Id. ¶ 15.

¶ 12 C. Postconviction Proceedings

¶ 13 In September 2015, defendant filed a pro se postconviction petition, asserting

many claims, including an allegation she was denied due process when the trial court denied her

request for an interpreter. The postconviction proceedings were lengthy. They involved three

amended complaints. Assistant Public Defender Jeff Brown filed the first amended petition. In

that petition, counsel asserted two claims, but he did not include the claim defendant was denied

due process when she was denied an interpreter. After the public defender’s office withdrew as

-4- counsel due to a conflict of interest, new counsel, Joshua Rinker, was appointed to represent

defendant. In the second amended postconviction petition, Rinker added a claim but did not

reassert defendant’s claim she should have been provided an interpreter. See People v. Nowlin,

2021 IL App (4th) 190851-U, ¶¶ 30-31, 33. After the dismissal of the second amended

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Cite This Page — Counsel Stack

Bluebook (online)
2025 IL App (4th) 230770-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-nowlin-illappct-2025.