People v. Sandoval

2020 IL App (1st) 172179-U
CourtAppellate Court of Illinois
DecidedSeptember 4, 2020
Docket1-17-2179
StatusUnpublished

This text of 2020 IL App (1st) 172179-U (People v. Sandoval) 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. Sandoval, 2020 IL App (1st) 172179-U (Ill. Ct. App. 2020).

Opinion

2020 IL App (1st) 172179-U FIFTH DIVISION SEPTEMBER 4, 2020

No. 1-17-2179

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 FIRST JUDICIAL DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Cook County. ) v. ) No. 88 CR 2755 ) FRANCISCO SANDOVAL, ) Honorable ) Timothy J. Joyce, Defendant-Appellant. ) Judge Presiding. _________________________________________________________________________

JUSTICE CUNNINGHAM delivered the judgment of the court. Presiding Justice Delort and Justice Rochford concurred in the judgment.

ORDER

¶1 Held: The trial court did not err in dismissing the defendant’s postconviction petition.

¶2 Following his conviction for first degree murder and aggravated battery, the defendant-

appellant, Francisco Sandoval, filed a pro se postconviction petition. The defendant now appeals.

For the following reasons, we affirm the judgment of the circuit court of Cook County.

¶3 BACKGROUND

¶4 In the interest of clarity and brevity, we will present only the facts pertinent to this order.

For a full recitation of facts leading up to this appeal, see People v. Sandoval, No. 1-09-2415 1-17-2179

(2011) (unpublished order under Illinois Supreme Court Rule 23(c)).

¶5 In February 1988, the defendant was charged with first degree murder, aggravated battery,

and armed violence for a shooting that occurred on September 6, 1978. The shooting, which

happened at 16th Street and Union Avenue in Chicago, killed Armando Ruiz and severely injured

Elizabeth Banda-Dammar. During her hospitalization, Ms. Banda-Dammar identified the

defendant, in a police photograph, as the shooter.

¶6 Ten years later, in 1988, the police located the defendant in California and extradited him

to Chicago. At the police station, the police interviewed the defendant and he made an inculpatory

statement indicating that he was involved in the shooting. Ms. Banda-Dammar also positively

identified the defendant, in a police lineup, as the shooter.

¶7 The defendant was then charged with first degree murder, aggravated battery, and armed

violence. The defendant posted bail and was released on bond. The defendant subsequently

appeared at a few court dates, but he failed to appear in court on September 14, 1988. Thereafter,

a warrant was issued for the defendant’s arrest. On January 11, 2006, the defendant was located in

California. He was, again, arrested and extradited to Chicago.

¶8 On May 27, 2009, a jury trial commenced. Ms. Banda-Dammar testified and positively

identified the defendant in court as the shooter. The defendant did not testify and did not present

any evidence of an alibi. At the conclusion of the trial, the defendant was found guilty of first

degree murder and aggravated battery. The trial court sentenced the defendant to 35 years’

imprisonment for first degree murder and 5 years’ imprisonment for aggravated battery, to be

served concurrently.

-2- 1-17-2179

¶9 On direct appeal, the defendant argued that he received ineffective assistance of counsel

when his defense counsel failed to: file a motion to suppress Ms. Banda-Dammar’s police lineup

identification; object to Ms. Banda-Dammar’s in-court identification; and present a credible

defense to the jury. Sandoval, No. 1-09-2415 at 5. He also argued that he was entitled to additional

sentencing credit for time served in pre-sentence custody. Id. This court rejected the defendant’s

ineffective assistance of counsel arguments and affirmed his convictions. Id. at 8. We also ordered

the mittimus corrected to reflect the defendant’s proper credit for pre-sentence custody. Id. at 9-

10.

¶ 10 On April 28, 2017, the defendant filed the pro se postconviction petition at issue. His

petition alleged that he received ineffective assistance of trial counsel because his defense counsel

failed to investigate two alibi witnesses: his brother, Efren Sandoval (Efren), and his girlfriend at

the time of the shooting, Elba Ruiz (Elba). In his petition, the defendant alleged that Efren and

Elba “could have corroborated” his alibi and testified that he was living in California at the time

of the shooting. The defendant accordingly argued that he received ineffective assistance when his

defense counsel failed to contact Efren and Elba or call them as witnesses. The defendant’s petition

also alleged that he was actually innocent, that he had been coerced into giving an inculpatory

statement, and that the trial court failed to properly admonish him that he is required to serve a

term of mandatory supervision upon his release.

¶ 11 On May 12, 2017, the trial court entered an order dismissing the defendant’s petition. The

trial court dismissed the defendant’s ineffective assistance of counsel claim on several grounds.

First, the trial court found that the defendant had waived the claim because he did not raise it in

his direct appeal. The trial court further held that, regardless of waiver, the defendant’s ineffective

-3- 1-17-2179

assistance of counsel claim was meritless where the decision to call witnesses is a matter of trial

strategy. And finally, the trial court noted that, even if the defendant’s claim had merit, the

defendant neither attached affidavits from Efren and Elba nor explained why they were not

attached. The trial court stated that this failure was “fatal to [the defendant’s] claim.” The

defendant subsequently appealed.

¶ 12 ANALYSIS

¶ 13 We note that we have jurisdiction to review the trial court’s judgment, as this court allowed

the defendant to file a late notice of appeal. Ill. S. Ct. R. 603 (eff. Feb. 6, 2013); R. 606(c) (eff.

July 1, 2017).

¶ 14 The defendant raises the following sole issue: whether the trial court erred in dismissing

his postconviction petition claim that he received ineffective assistance of counsel. 1 The defendant

argues that his petition established an arguable basis that he received ineffective assistance of

counsel when his defense counsel failed to investigate Efren and Elba or call them as alibi

witnesses. The defendant claims that, postconviction petitions in the first stage of proceedings,

such as his, are “judged by a lower pleading standard” and “construed liberally.” Relying upon

People v. Hodges, 234 Ill. 2d 1 (2009), the defendant avers that it was not necessary for him to

attach affidavits from Efren and Elba during the first stage of proceedings, especially since he was

filing the petition pro se while imprisoned. He asks us to remand the case back to the trial court

and order further proceedings on his petition.

¶ 15 The Post-Conviction Hearing Act (Act) provides a procedural mechanism through which

a criminal defendant can assert that his constitutional rights were substantially violated in his

1 The defendant does not challenge the trial court’s dismissal of his other postconviction petition claims.

-4- 1-17-2179

original trial or sentencing hearing. 725 ILCS 5/122-1 (West 2016); People v. Pitsonbarger, 205

Ill. 2d 444, 455 (2002).

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Related

People v. Hodges
912 N.E.2d 1204 (Illinois Supreme Court, 2009)
People v. Pitsonbarger
793 N.E.2d 609 (Illinois Supreme Court, 2002)
People v. Allen
2015 IL 113135 (Illinois Supreme Court, 2015)
People v. Wideman
2013 IL App (1st) 102273 (Appellate Court of Illinois, 2013)
People v. Brown
2017 IL App (1st) 142877 (Appellate Court of Illinois, 2017)
People v. Gallano
2019 IL App (1st) 160570 (Appellate Court of Illinois, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
2020 IL App (1st) 172179-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-sandoval-illappct-2020.