People v. Seal

2020 IL App (4th) 180100-U
CourtAppellate Court of Illinois
DecidedMarch 10, 2020
Docket4-18-0100
StatusUnpublished

This text of 2020 IL App (4th) 180100-U (People v. Seal) 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. Seal, 2020 IL App (4th) 180100-U (Ill. Ct. App. 2020).

Opinion

NOTICE FILED This order was filed under Supreme 2020 IL App (4th) 180100-U March 10, 2020 Court Rule 23 and may not be cited Carla Bender as precedent by any party except in th the limited circumstances allowed NO. 4-18-0100 4 District Appellate under Rule 23(e)(1). Court, IL IN THE APPELLATE COURT

OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee ) Circuit Court of v. ) Sangamon County MICHAEL SEAL, ) No. 09CF998 Defendant-Appellant. ) ) Honorable ) John Madonia, ) Judge Presiding.

PRESIDING JUSTICE STEIGMANN delivered the judgment of the court. Justices Knecht and DeArmond concurred in the judgment.

ORDER

¶ 1 Held: The appellate court affirmed the trial court’s denial of defendant’s posttrial mo- tion.

¶2 In November 2017, a jury found defendant, Michael Seal, guilty of first degree

murder, and the trial court later sentenced him to 40 years in prison. Defendant appeals, arguing

only that the trial court failed to conduct (1) a pretrial Krankel inquiry and (2) a posttrial Krankel

inquiry. See People v. Krankel, 102 Ill. 2d 181, 464 N.E.2d 1045 (1984). We disagree and af-

firm.

¶3 I. BACKGROUND

¶4 In November 2009, the State charged defendant with first degree murder (720

ILCS 5/9-1(a)(1), (2) (West 2008)). The November 2017 jury trial at issue in this appeal at

which defendant was convicted was his second trial on that charge. Defendant’s first trial was an August 2012 bench trial at which the trial court found defendant guilty of first degree murder and

later sentenced him to 40 years in prison.

¶5 Because defendant’s arguments on appeal do not involve either the adequacy or

the nature of the evidence presented against him at trial, we refer to that evidence only to the ex-

tent necessary to put defendant’s arguments in the appropriate context.

¶6 A. Defendant’s First Trial

¶7 After the State charged defendant in November 2009 with first degree murder, the

Sangamon County public defender was appointed to represent him. As the parties prepared for

trial, defendant filed pro se numerous letters, affidavits, and motions complaining of the repre-

sentation provided for him by his attorney from the public defender’s office. Part of the diffi-

culty between defendant and his counsel, as counsel explained to the trial court in March 2011,

was that defendant wanted counsel to file motions counsel deemed frivolous and counsel refused

to file them.

¶8 Between February 2011 and March 2012, defendant pro se filed many motions

complaining about counsel, one of which asserted that his counsel “must abide by the client[’]s

decision as to how the representation is handled.” In March 2012, defendant pro se filed a “mo-

tion of ineffective assistance of counsel,” which contained numerous complaints about his coun-

sel’s representation.

¶9 Ultimately, in April 2012, defendant filed a “motion to proceed pro se,” alleging

that he was forced to represent himself because the court had refused to appoint new counsel, co-

counsel, or advisory counsel. In May 2012, the trial court conducted a hearing on defendant’s

motion, purportedly admonished him pursuant to Illinois Supreme Court Rule 401 (eff. July 1,

1984), and additionally admonished him at length in accordance with the suggestions of this

-2- court in People v. Williams, 277 Ill. App. 3d 1053, 1056-57, 661 N.E.2d 1186, 1189 (1996). The

court thereafter accepted defendant’s waiver of counsel, and in July 2012, defendant waived his

right to a trial by jury.

¶ 10 In August 2012, the trial court conducted a bench trial at which defendant did not

testify. The court found defendant guilty of first degree murder and appointed counsel to assist

defendant with posttrial motions and at sentencing. In July 2013, the court conducted a sentenc-

ing hearing and sentenced defendant to 40 years in prison.

¶ 11 B. Defendant’s First Appeal

¶ 12 Defendant appealed his conviction, arguing that his pretrial waiver of counsel was

invalid because the trial court did not provide him with the admonitions required by Rule 401 be-

fore accepting that waiver. This court agreed with defendant’s argument, reversed his convic-

tion, and remanded for a new trial. People v. Seal, 2015 IL App (4th) 130775, 38 N.E.3d 642

(Seal I). In so concluding, this court noted that in November 2009 defendant (1) first appeared

on this charge, (2) was provided with a copy of the charge against him, and (3) was advised of

the possible penalties he faced. However, nearly 2½ years after defendant was initially so ad-

vised, the trial court did not again admonish him regarding these matters pursuant to Rule 401

when defendant stated he wished to proceed pro se. Instead, the court only advised defendant of

the problems he would likely face as a pro se defendant as this court described them in Williams.

¶ 13 The flavor of the trial court proceedings at defendant’s first trial was captured in a

special concurrence written in Seal I by this order’s author:

“Defendant, convicted of first degree murder, gamed the system and got

away with it. Although I agree with the majority opinion, I write this special con-

currence to emphasize the mistakes the trial court made in this case. I do so in the

-3- hope that this discussion will keep other trial courts from committing the same er-

rors.

The fundamental error the trial court committed was granting credence to

defendant’s unceasing complaints about his court-appointed lawyers and then

changing those lawyers in a predictably vain effort to somehow assuage defend-

ant.

***

The trial court’s other key error in the handling of this difficult defendant

was the court’s indulging him with regard to his spurious pro se motions. Having

once explained to defendant that there was no such thing as hybrid representation

and that he could either have the services of court-appointed counsel or represent

himself, the court (at a hearing with defendant present) should have routinely

stricken all pro se motions filed by defendant that his counsel did not adopt and

pursue. The court was under no obligation to consider any of these motions and

erred by doing so.” Seal I, ¶¶ 38-39, 47 (Steigmann, J., specially concurring).

¶ 14 C. Defendant’s Second Trial

¶ 15 On remand, the trial court granted defendant’s request to be represented by court-

appointed counsel and again appointed the Sangamon County public defender to represent de-

fendant. Defendant again began to file pro se various motions, including one that complained it

was prejudicial and a “conflict of interest” to force him to accept as counsel an attorney that de-

fendant had previously fired. He also complained about that attorney’s failure to raise certain

factual issues.

¶ 16 Months later, defendant’s counsel indicated that defendant had a change of heart

-4- and was then consenting to his representation. However, after defendant’s counsel informed the

court that due to his caseload with respect to other clients charged with murder, he would not be

able to proceed with defendant’s case for at least five months, defendant then stated he wished to

proceed pro se. Ultimately, the trial court granted defendant’s request to represent himself, and

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Related

People v. Williams
661 N.E.2d 1186 (Appellate Court of Illinois, 1996)
People v. Krankel
464 N.E.2d 1045 (Illinois Supreme Court, 1984)
People v. Jocko
940 N.E.2d 59 (Illinois Supreme Court, 2010)
People v. Patrick
960 N.E.2d 1114 (Illinois Supreme Court, 2011)
People v. Seal
2015 IL App (4th) 130775 (Appellate Court of Illinois, 2015)
People v. Seal
2015 IL App (4th) 130775 (Appellate Court of Illinois, 2015)
People v. Patrick
2011 IL 111666 (Illinois Supreme Court, 2011)
People v. Ayres
2017 IL 120071 (Illinois Supreme Court, 2018)
People v. Roddis
2020 IL 124352 (Illinois Supreme Court, 2021)

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2020 IL App (4th) 180100-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-seal-illappct-2020.