People v. Pryor

2020 IL App (2d) 170926-U
Appellate Court of Illinois·Decided March 18, 2020·No. 2-17-0926·Unpublished

Opinion

2020 IL App (2d) 170926-U No. 2-17-0926 Order filed March 18, 2020

NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

SECOND DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE ) Appeal from the Circuit Court OF ILLINOIS, ) of Kane County. ) Plaintiff-Appellee, ) ) v. ) No. 16-CF-827 ) NATHANIEL PRYOR, ) Honorable ) M. Katherine Moran, Defendant-Appellant. ) Judge, Presiding. ______________________________________________________________________________

JUSTICE HUDSON delivered the judgment of the court. Presiding Justice Birkett and Justice Bridges concurred in the judgment.

ORDER

¶1 Held: The trial court properly summarily dismissed defendant’s postconviction petition, which alleged that his guilty plea was induced by ineffective assistance of counsel: defendant’s claim that he was unaware that he was subject to mandatory supervised release (MSR) was refuted by the record, which showed that the court so admonished him, and therefore his assertion that he would have rejected plea offer of time served and MSR was not rational under the circumstances.

¶2 Defendant, Nathaniel Pryor, appeals the summary dismissal of his postconviction petition.

He contends that he stated the gist of claims that (1) he was denied due process and (2) his counsel

was ineffective during proceedings resulting in his guilty plea. We affirm.

¶3 I. BACKGROUND 2020 IL App (2d) 170926-U

¶4 Defendant was charged with two counts of domestic battery (720 ILCS 5/12-3.2 (West

2016)). He agreed to plead guilty to one count in exchange for a one-year prison sentence and a

four-year term of mandatory supervised release (MSR). The one-year prison term was to be

concurrent with a six-year term imposed in an unrelated case. The trial court admonished

defendant that he would receive credit for 247 days already served “and then followed by four

years of [MSR] after you are released from the department of corrections.”

¶5 Defendant said that he “wasn’t aware of any of that.” The court allowed defendant to

consult with his attorney, following which the court again admonished him that he would “get a

year in the department of corrections *** with 247 days served *** and a four-year period of

[MSR].”

¶6 The court found that the plea was voluntary. The factual basis for the plea showed that

defendant and the victim had a relationship and shared a child. On April 23, 2016, defendant

argued with the victim and struck her, causing scratches and red marks on her face. The court

found defendant guilty and imposed the agreed-upon sentence. The court explained that the

sentence would be followed by a four-year MSR period and that “this sentence will run concurrent”

with the other sentence.

¶7 Defendant did not move to withdraw the plea or appeal. However, on July 24, 2017, he

filed a pro se postconviction petition. He alleged that his attorney had led him to believe that his

MSR term would run while he was serving his six-year sentence in the other case, meaning that

he would have to serve only the two-year MSR term attached to that sentence. He alleged that, if

he had known that the MSR term would not begin until his release from prison, he would not have

pleaded guilty and would have demanded a jury trial.

-2- 2020 IL App (2d) 170926-U

¶8 The trial court summarily dismissed the petition, finding that defendant did not establish

that he failed to understand the terms of his sentence. Defendant timely appeals.

¶9 II. ANALYSIS

¶ 10 Although defendant claims both a denial of due process and the ineffective assistance of

counsel, both contentions are based on the allegation that defense counsel gave him the mistaken

impression that he could serve his MSR term in this case while serving his prison sentence in the

unrelated case. He contends that, had he known that he would have to serve the four-year MSR

term after completing the six-year sentence, he would not have accepted the plea agreement and

would have insisted on a jury trial.

¶ 11 The Post-Conviction Hearing Act (725 ILCS 5/122-1 et seq. (West 2018)) permits a

defendant to challenge his conviction for violations of his federal or state constitutional rights.

People v. Whitfield, 217 Ill. 2d 177, 183 (2005). At the first stage of proceedings, the trial court

must independently review the petition within 90 days of its filing and decide whether “the petition

is frivolous or is patently without merit.” 725 ILCS 5/122-2.1(a)(2) (West 2018). To survive this

review, a petition need set forth only the gist of a constitutional claim. People v. Edwards, 197 Ill.

2d 239, 244 (2001). The petition “ ‘need only present a limited amount of detail.’ ” Id. (quoting

People v. Gaultney, 174 Ill. 2d 410, 418 (1996)).

¶ 12 To prevail on a claim of ineffective assistance of counsel, a defendant must establish that

(1) counsel’s performance was objectively unreasonable and (2) the defendant was prejudiced

thereby. Strickland v. Washington, 466 U.S. 668, 687-88 (1984); People v. Tucek, 2019 IL App

(2d) 160788, ¶ 14. In the guilty-plea context, a defendant must raise the gist of a meritorious

allegation that it is reasonably probable that, absent counsel’s error, defendant would not have

pleaded guilty but would have insisted on going to trial. Id., ¶ 17. This requires more than “ ‘[a]

-3- 2020 IL App (2d) 170926-U

conclusory allegation’ ” to that effect. Id. (quoting People v. Valdez, 2016 IL 119860, ¶ 29).

Rather, the petition must plead facts to show that the decision to reject the plea bargain would have

been rational under the circumstances. Id. While a defendant need not articulate a claim of

innocence or a plausible defense, he must raise more than a bare allegation that, absent counsel’s

errors, he would have rejected the plea offer and proceeded to trial. Id. ¶ 18. The potential

penalties and the probability of an acquittal (which contemplates the existence of a plausible

defense) are among the relevant circumstances. Id.

¶ 13 Here, the petition contained no more than a conclusory allegation that, but for counsel’s

allegedly faulty advice, defendant would have rejected the plea offer and insisted on a jury trial.

Essentially, defendant pleaded guilty in exchange for time served. In practical terms, the only

benefit of an acquittal, which was by no means a certainty, was the avoidance of the additional

MSR period. Defendant does not articulate a plausible defense he could have raised at trial. Nor

does he allege that he contemporaneously informed either his attorney or the court that the MSR

issue was of singular importance to him. As the plea agreement required defendant to serve no

additional prison time, it would, without additional facts, appear irrational to risk more prison time

solely to avoid additional time on MSR. Defendant alleges no facts to show that, due to unusual

circumstances, the issue was particularly important to him.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
People v. Whitfield
840 N.E.2d 658 (Illinois Supreme Court, 2005)
People v. Gaultney
675 N.E.2d 102 (Illinois Supreme Court, 1996)
People v. Edwards
757 N.E.2d 442 (Illinois Supreme Court, 2001)
People v. Valdez
2016 IL 119860 (Illinois Supreme Court, 2016)
Jae Lee v. United States
582 U.S. 357 (Supreme Court, 2017)
People v. Hoare
2018 IL App (2d) 160727 (Appellate Court of Illinois, 2018)
People v. Tucek
2019 IL App (2d) 160788 (Appellate Court of Illinois, 2019)