People v. Ruffin

2025 IL App (4th) 241192-U
CourtAppellate Court of Illinois
DecidedDecember 4, 2025
Docket4-24-1192
StatusUnpublished

This text of 2025 IL App (4th) 241192-U (People v. Ruffin) 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. Ruffin, 2025 IL App (4th) 241192-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (4th) 241192-U NOTICE FILED This Order was filed under December 4, 2025 Supreme Court Rule 23 and is NO. 4-24-1192 Carla Bender not precedent except in the th 4 District Appellate limited circumstances allowed 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. ) Winnebago County JOHNNY M. RUFFIN, ) No. 99CF2060 Defendant-Appellant. ) ) Honorable ) Ronald J. White ) Judge Presiding.

JUSTICE KNECHT delivered the judgment of the court. Presiding Justice Harris and Justice Cavanagh concurred in the judgment.

ORDER

¶1 Held: The appellate court affirmed the trial court’s order denying defendant leave to file a successive postconviction petition, holding (1) defendant’s motion for leave to file a late appeal was timely filed, allowing the appellate court to gain jurisdiction over the appeal and (2) defendant could not show cause for leave to file a successive petition to challenge the conduct of appellate postconviction counsel during an earlier postconviction proceeding.

¶2 Following a jury trial, defendant, Johnny M. Ruffin, was convicted of one count

of second degree murder (720 ILCS 5/9-2 (West 1998)) for killing Brad Plaza and two counts of

aggravated battery with a firearm (id. § 5/12-4.2(a)(1)) for shooting Michael Vella and

Christopher Cummings. We affirmed defendant’s convictions and sentences on direct appeal.

People v. Ruffin, No. 2-00-0336 (2001) (unpublished order under Illinois Supreme Court Rule

23).

¶3 Defendant later filed a third amended petition under the Post-Conviction Hearing Act (Act) (725 ILCS 122-1 et seq. (West 2014)), alleging, in part, his trial counsel rendered

ineffective assistance by failing to inform him of his right to tender a jury instruction on reckless

conduct as a lesser-included offense of aggravated battery with a firearm. He also alleged the

State violated Brady v. Maryland, 373 U.S. 83 (1963), by failing to disclose exculpatory

evidence that Cummings was previously charged with misdemeanor battery. After a third-stage

evidentiary hearing, the trial court granted a new trial based on the alleged Brady violation and

denied relief on the remaining issues. The State appealed, and the appellate court reversed.

People v. Ruffin, 2018 IL App (2d) 170324-U, ¶ 34. Defendant’s postconviction counsel did not

raise any issues concerning the jury instructions on appeal.

¶4 In January 2024, defendant filed a pro se motion for leave to file a successive

postconviction petition, alleging, in part, postconviction counsel rendered ineffective assistance

by failing to file a cross-appeal regarding the trial court’s denial of his claim of ineffective

assistance of trial counsel based on the failure to inform defendant of his right to tender a jury

instruction on reckless conduct. The court denied leave to file the successive petition.

¶5 On appeal, defendant argues he established cause and prejudice to file the

successive postconviction petition because he established (1) unreasonable assistance of

postconviction counsel based on counsel’s failure to raise the issue of ineffective assistance of

trial counsel in the State’s appeal and (2) ineffective assistance of trial counsel based on

counsel’s failure to inform him of his right to a reckless conduct instruction.

¶6 We find the postconviction process does not provide a forum by which defendant

may challenge the conduct of counsel at an earlier postconviction proceeding. Regarding the

claim of ineffective assistance of trial counsel, it is res judicata. Further, even if we were

authorized to address defendant’s claims, they lack merit because defendant could not show

-2- prejudice. Accordingly, we affirm.

¶7 I. BACKGROUND

¶8 In July 1999, defendant was charged with four counts of first degree murder (720

ILCS 5/9-1(a)(1), (2) (West 1998)) and two counts of aggravated battery with a firearm (id. § 12-

4.2(a)). In early 2000, a jury trial was held. Defendant was represented at trial by attorneys

Edward Light and Gary Pumilia.

¶9 The evidence at trial showed that, on June 26, 1999, defendant became involved

in an altercation among a group of people. During the altercation, defendant shot and killed

Plaza. Defendant also shot and injured Cummings and Vella. Defendant testified he ran away

from the group but shot Plaza twice after a group of six or seven people came close to him and

he believed they were going to grab his gun and shoot him. Defendant said he fired five more

shots into the ground because he did not want to hurt anyone.

¶ 10 After shooting the victims, defendant stole a vehicle at gunpoint. The police

engaged in a high-speed pursuit, which resulted in defendant crashing the car. Defendant pointed

his gun at the police, who shot defendant in response.

¶ 11 Defendant’s trial counsel asserted self-defense and tendered jury instructions on

self-defense and second degree murder as a lesser mitigated offense of first degree murder (id.

§ 9-2). Counsel did not request instructions on any lesser-included offenses of aggravated battery

with a firearm. During the jury instruction conference, defendant said he had “some

dissatisfaction” with his trial counsel. He indicated he did not fully agree with their position

regarding two instructions not at issue in this appeal. Defendant stated he agreed with the

decision to tender the second degree murder instruction. The trial court gave that instruction to

the jury.

-3- ¶ 12 The jury found defendant guilty of one count of second degree murder for killing

Plaza and two counts of aggravated battery with a firearm for shooting Vella and Cummings.

The trial court sentenced defendant to consecutive terms of 25 years’ imprisonment for each of

the two counts of aggravated battery and 19 years’ imprisonment for second degree murder.

Defendant appealed but did not raise any issues concerning his trial counsel’s decision not to

tender an instruction on reckless conduct as a lesser-included offense of aggravated battery with

a firearm. The appellate court affirmed. Ruffin, No. 2-00-0336 (2001) (unpublished order under

Illinois Supreme Court Rule 23).

¶ 13 In February 2002, defendant filed a pro se postconviction petition, alleging

multiple issues, including a claim of ineffective assistance of trial counsel based on counsel’s

failure to tender a jury instruction on reckless conduct. Defendant alleged counsel incorrectly

told him there were no lesser-included offenses of aggravated battery with a firearm, which

caused him to involuntarily forfeit his right to tender a reckless conduct instruction. He argued

such an instruction was warranted because the evidence showed he did not intentionally fire

shots at Vella and Cummings and instead fired the shots that hit them into the ground.

¶ 14 At the second stage of the postconviction proceedings, the trial court granted the

State’s motion to dismiss the petition. Defendant appealed, arguing (1) unreasonable assistance

of postconviction counsel when counsel did not make any amendments to the pro se petition and

(2) ineffective assistance of trial counsel when counsel did not inform defendant of his right to

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Bluebook (online)
2025 IL App (4th) 241192-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-ruffin-illappct-2025.