People v. Stufflebeam

2025 IL App (4th) 240825-U
CourtAppellate Court of Illinois
DecidedJuly 1, 2025
Docket4-24-0825
StatusUnpublished

This text of 2025 IL App (4th) 240825-U (People v. Stufflebeam) 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. Stufflebeam, 2025 IL App (4th) 240825-U (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (4th) 240825-U FILED This Order was filed under July 1, 2025 Supreme Court Rule 23 and is NO. 4-24-0825 Carla Bender not precedent except in the 4th District Appellate limited circumstances allowed Court, IL under Rule 23(e)(1). IN THE APPELLATE COURT

OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) Tazewell County JOHN D. STUFFLEBEAM, ) No. 08CF97 Defendant-Appellant. ) ) Honorable ) Christopher R. Doscotch, ) Judge Presiding.

JUSTICE GRISCHOW delivered the judgment of the court. Justices Zenoff and Cavanagh concurred in the judgment.

ORDER

¶1 Held: The appellate court affirmed the second-stage dismissal of defendant’s second amended postconviction petition because defendant failed to make a substantial showing trial counsel provided ineffective assistance during plea negotiations.

¶2 A jury convicted defendant, John D. Stufflebeam, of two counts of predatory

criminal sexual assault of a child (720 ILCS 5/12-14.1(a)(1) (West 2006)). He was subsequently

sentenced to two consecutive terms of 14 years’ imprisonment, for an aggregate term of 28

years. Thereafter, defendant petitioned pro se for postconviction relief, the trial court summarily

dismissed the petition, defendant appealed, and the Appellate Court, Third District, reversed and

remanded. On remand, postconviction counsel was appointed and filed a second amended

postconviction petition, alleging trial counsel’s erroneous advice about defendant’s statutory

right to a speedy trial resulted in defendant rejecting the State’s plea offers and proceeding with a

jury trial. The State moved to dismiss, and the trial court granted the State’s motion. Defendant appeals. We affirm.

¶3 I. BACKGROUND

¶4 Defendant was arrested on March 6, 2008, for sexually assaulting M.B., a

four-year-old boy. Soon thereafter, Kirk Bode was appointed to represent defendant. Defendant

remained in jail and was brought to trial on October 14, 2008.

¶5 Between March 6, 2008, and October 14, 2008, several pretrial motions were filed

by both parties. On May 13, 2008, while several of the State’s pretrial motions were pending,

Bode moved for, among other things, a psychiatric examination of defendant, claiming there was

a bona fide doubt about defendant’s fitness to stand trial and sanity at the time the crimes were

committed. Bode believed this motion did not toll the time the State had to bring defendant to

trial. Thus, on July 1, 2008, Bode moved to dismiss the indictment and release defendant from

custody, claiming defendant’s statutory speedy trial right was violated, as defendant had been in

continuous custody for 120 days. See 725 ILCS 5/103-5 (West 2008).

¶6 On September 3, 2008, a hearing on Bode’s motion to dismiss was held. Bode

asserted at the hearing that the “primary issue” was whether his motion for a psychiatric exam

tolled the 120 days the State had to bring defendant to trial. The trial court denied the motion to

dismiss.

¶7 The case proceeded to trial, and defendant was convicted and sentenced. He

appealed, and his convictions and sentences were affirmed (People v. Stufflebeam, No.

3-08-1038 (2011) (unpublished order under Illinois Supreme Court Rule 23)).

¶8 On March 5, 2012, defendant filed a pro se petition for postconviction relief. In

his petition, he alleged, among other things:

“After the hearing on the psychiatric examination, [Bode] told Defendant

-2- and his family, that the judge would probably grant the motion for psychiatric

examination because that would toll the clock on the speedy trial. If he denied it,

the clock would continue to run, and he would violate speedy trial. *** This

resulted in the Defendant foregoing a favorable plea agreement and any further

negotiations, so that he could exercise his right to appeal [citation].

***

*** As this issue has relied on matters outside the record, Appellate

Counsel could not have argued it on Direct Appeal.”

¶9 Attached to the petition were affidavits prepared by defendant and his father and

brother. In his affidavit, defendant attested, “The [S]tate had agreed to a plea bargain of 14 years

at 85%, but because I believed my speedy trial right had been violated, and I would win on

appeal, I was unwilling to negotiate.” (Emphases added.)

¶ 10 Defendant’s father attested that, after the June 30, 2008, hearing, “Bode told me

that [h]e was sure the judge would grant the motion for psychiatric examination. *** Bode went

on to explain that if a psychiatric examination were ordered by the judge[,] then the clock on the

speedy trial would be extended and more time would be afforded.”

¶ 11 Similarly, defendant’s brother attested:

“On [June 30, 2008,] after the hearing, *** Bode met with us to explain

what happened in the hearing. He said that he asked for a psychological

evaluation [sic] for [defendant] and that the judge would most likely approve it to

‘stop the clock.’ Otherwise[,] they would violate[defendant’s] right to a speedy

trial.”

¶ 12 The trial court summarily dismissed defendant’s petition, and he appealed.

-3- ¶ 13 The Appellate Court, Third District, reversed and remanded for proceedings under

stage two of the Post-Conviction Hearing Act (Act) (725 ILCS 5/122-1 et seq. (West 2014)). See

People v. Stufflebeam, 2014 IL App (3d) 120317-U, ¶ 27. In so doing, the court observed, under

People v. Curry, 178 Ill. 2d 509, 530 (1997), a defendant who claims his trial counsel was

ineffective in advising him to reject a plea offer must establish (1) counsel’s performance fell

below an objective standard of reasonableness during plea bargaining (deficient performance)

and (2) the defendant would have accepted the plea offer but for counsel’s erroneous advice

(prejudice prong). Stufflebeam, 2014 IL App (3d) 120317-U, ¶ 21. The court then noted this law

was modified on March 21, 2012, 16 days after defendant filed his petition, when the United

States Supreme Court decided Missouri v. Frye, 566 U.S. 134 (2012), and Lafler v. Cooper, 566

U.S. 156 (2012). Under these cases, a defendant who claims his attorney was ineffective for

advising him to reject a plea offer must establish, pursuant to the prejudice prong, (1) he would

have accepted the plea offer if his attorney had not provided erroneous advice; (2) the plea would

have been presented to the trial court, i.e., the defendant would have accepted the plea offer and

the State would not have withdrawn the offer because of intervening circumstances; (3) the trial

court would have accepted the terms of the plea offer; and (4) the conviction, sentence, or both

would have been less severe under the plea offer’s terms than under the judgment and sentence

that were in fact imposed (Frye, 566 U.S. at 147; Lafler, 566 U.S. at 164). Stufflebeam, 2014 IL

App (3d) 120317-U, ¶ 22. The appellate court found defendant’s ineffective assistance claim

“arguably would not have been sufficient *** after March 21, 2012.” Id. ¶ 24. However,

defendant’s petition was filed before March 21, 2012. Id. Thus, the court found Curry, not Lafler

and Frye, controlled. Id. The court determined, “Under Curry, defendant adequately alleged facts

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2025 IL App (4th) 240825-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-stufflebeam-illappct-2025.