People v. Patton

2025 IL App (5th) 230405-U
CourtAppellate Court of Illinois
DecidedJanuary 3, 2025
Docket5-23-0405
StatusUnpublished

This text of 2025 IL App (5th) 230405-U (People v. Patton) 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. Patton, 2025 IL App (5th) 230405-U (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (5th) 230405-U NOTICE Decision filed 01/03/25. The This order was filed under text of this decision may be NO. 5-23-0405 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, ) Vermilion County. ) v. ) No. 20-CF-114 ) DAKOTA PATTON, ) Honorable ) Charles C. Hall, Defendant-Appellant. ) Judge, presiding. ______________________________________________________________________________

JUSTICE SHOLAR delivered the judgment of the court. Justices Cates and Moore concurred in the judgment.

ORDER

¶1 Held: The trial court erred by failing to appoint separate counsel after conducting a hearing pursuant to People v. Krankel, 102 Ill. 2d 181 (1984). We remand this case to the circuit court with directions to conduct a full Krankel hearing, including the appointment of new counsel to evaluate defendant’s pro se claim of ineffective assistance of trial counsel.

¶2 Defendant, Dakota Patton, appeals the decision of the Vermilion County trial court denying

his request for the appointment of independent counsel to investigate and argue defendant’s claim

of ineffective assistance of trial counsel. For the reasons that follow, we reverse and remand for

the appointment of independent counsel and for further Krankel proceedings.

¶3 I. BACKGROUND

¶4 This is defendant’s second appeal to the appellate court. See People v. Patton, 2022 IL App

(4th) 210561. In defendant’s prior appeal, the Fourth District affirmed the denial of defendant’s

1 motion to suppress evidence (id. ¶ 96) but concluded that the record was inadequate to review

defendant’s claim that the trial court erred by failing to conduct a Krankel inquiry into defendant’s

claims of ineffective assistance of counsel. Id. ¶ 115. The Fourth District remanded with

instructions for the trial court to inquire into defendant’s posttrial claim that he was denied his

right to testify. Id. ¶ 123. Due to the recitation of facts in the earlier appeal, we borrow liberally

from the Fourth District’s opinion and recite only the facts necessary for the resolution of this

appeal. See Patton, 2022 IL App (4th) 210561.

¶5 On February 14, 2020, police officers in Danville responded to a call of shots fired.

Defendant was a passenger in a pickup truck stopped by the police as a part of the investigation.

The driver of the pickup truck, Robert Phillips, consented to a search of the truck. While searching

the vehicle, the police found a .380 Ruger pistol that was immediately accessible to defendant. The

police took swabs of the pistol grip and trigger for deoxyribonucleic acid (DNA) and sent the

swabs to the Illinois State Police Forensic Crime Laboratory.

¶6 Defendant was charged with being an armed habitual criminal (count I) (720 ILCS 5/24-

1.7(a) (West 2018)), possession of a stolen firearm (count II) (id. § 24-3.8), and two counts of

possession of a weapon by a felon (counts III and IV) (id. § 24-1.1(a)). In December 2020,

defendant filed an amended motion to suppress evidence. The trial court denied defendant’s

motion at the conclusion of the February 2021 hearing.

¶7 On June 14, 2021, the trial court held a pretrial hearing and the matter was set for trial on

August 10, 2021. The matter was set for a guilty plea on July 1, 2021, but defendant changed his

mind and decided to proceed with the trial set on August 10. On July 13, 2021, the State filed a

motion for additional discovery and a motion for the consumption of samples. The State’s motion

noted that law enforcement swabbed the recovered firearm and requested that defendant permit

2 the taking of buccal swabs of his saliva for comparison with the DNA found on the firearm. The

State’s motions were granted. On July 30, 2021, 10 days prior to trial, the State disclosed to the

court that it had tendered the results of the DNA testing to the defense. At the beginning of August

2021, defense counsel filed various motions in limine in preparation for trial. The State likewise

filed a motion in limine in anticipation of trial.

¶8 On August 6, 2021, the case was called for a final pretrial hearing. The trial court ruled on

the parties’ motions in limine, including granting, should defendant testify, the State’s request to

impeach defendant with prior convictions.

¶9 On the morning of the trial, the parties appeared and requested a Rule 402(d) conference

(Ill. S. Ct. R. 402(d) (eff. July 1, 2012)) to be followed by a stipulated bench trial. The trial court

admonished defendant pursuant to Rule 402(d). Id. The court then advised defendant that he had

“a right to a jury trial, a jury of 12 people and you have the right to waive that and have a bench

trial with the judge only.” The court asked defendant if he had discussed this with his attorney, and

whether he was willing to waive a jury trial. Defendant responded, “Yeah, from what I understand,

yeah.” Defendant signed a jury waiver that simply stated that he waived his right to trial by jury

and consented to a bench trial.

¶ 10 Following the Rule 402(d) conference, the trial court reconvened and confirmed that the

parties were ready to proceed with a stipulated bench trial on count III, one of the counts alleging

possession of a weapon by a felon. Defendant was not informed, on the record, that the evidence

presented in his bench trial would be based solely upon written stipulations submitted to the court

by the parties. Defense counsel noted for the court that defendant was not stipulating to the

sufficiency of the evidence, but rather that the defendant was stipulating to the State’s evidence,

and the defense was doing this for the purpose of “fast tracking” the appeal process. Trial counsel

3 believed that there were grounds for an appeal based on motions previously decided by the court.

Three stipulations were submitted to and received by the court.

¶ 11 Relevant to this appeal, the stipulation regarding the driver of the pickup truck established

the following: Robert Phillips would testify that on February 14, 2020, he was driving a silver

Dodge pickup truck with Indiana plates when he was stopped by the police. Defendant was a

passenger in Phillips’s truck. Earlier that evening, defendant approached Phillips at his home and

told Phillips to give him a ride. Phillips “inferred from various actions that the defendant had a gun

on him,” and Phillips had “previously seen the defendant in possession of a .380 pistol.” Phillips

did not possess a gun that day. The stipulation regarding the DNA evidence established that the

firearm was tested for DNA and “the DNA found in one portion of swabbing from each of the grip

and the trigger/slide were consistent with having originated from” defendant.

¶ 12 Following the presentation of the stipulations, the State rested. Defendant rested without

presenting any evidence. The trial court found defendant guilty of the charge in count III. The State

dismissed the remaining counts and the matter was set for sentencing.

¶ 13 Three days after the stipulated bench trial, the trial court called a hearing. The court noted

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2025 IL App (5th) 230405-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-patton-illappct-2025.