People v. Sullivan

2023 IL App (4th) 220962-U
CourtAppellate Court of Illinois
DecidedJune 28, 2023
Docket4-22-0962
StatusUnpublished

This text of 2023 IL App (4th) 220962-U (People v. Sullivan) 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. Sullivan, 2023 IL App (4th) 220962-U (Ill. Ct. App. 2023).

Opinion

NOTICE 2023 IL App (4th) 220962-U This Order was filed under FILED Supreme Court Rule 23 and is June 28, 2023 NO. 4-22-0962 not precedent except in the Carla Bender limited circumstances allowed 4th District Appellate under Rule 23(e)(1). IN THE APPELLATE COURT Court, IL

OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) Mercer County MICHELLE L. SULLIVAN, ) No. 19CF11 Defendant-Appellant. ) ) Honorable ) Norma Kauzlarich, ) Judge Presiding. ______________________________________________________________________________

JUSTICE HARRIS delivered the judgment of the court. Justices Zenoff and Knecht concurred in the judgment.

ORDER

¶1 Held: Because defendant’s appeal lacks arguable merit, the Office of the State Appellate Defender is granted leave to withdraw as appellate counsel and the trial court’s judgment dismissing defendant’s pro se postconviction petition is affirmed.

¶2 Defendant, Michelle L. Sullivan, appeals the trial court’s dismissal of her pro se

postconviction petition. On appeal, this court appointed the Office of the State Appellate Defender

(OSAD) to represent her. OSAD has moved to withdraw as counsel, arguing defendant’s appeal

lacks arguable merit. We grant OSAD’s motion and affirm the court’s dismissal of defendant’s

postconviction petition.

¶3 I. BACKGROUND

¶4 In March 2019, the State charged defendant with obstructing justice (720 ILCS

5/31-4(a) (West 2018)), alleging she furnished false information to a law enforcement officer with the intent to prevent herself from being prosecuted. In February 2020, she pleaded guilty to

misdemeanor attempted obstruction of justice (id. §§ 8-4(a), 8-4(c)(5), 31-4(a)) pursuant to a fully

negotiated plea agreement with the State. Defendant was sentenced to 24 months’ conditional

discharge and 24 days in jail, the latter of which was stayed. She was also ordered to pay a $500

fine and $8064 in restitution. During a guilty plea hearing, the trial court found there was a factual

basis for defendant’s plea, although that factual basis was not set forth in the hearing transcript,

and it accepted defendant’s plea.

¶5 In December 2021, defendant appeared before the trial court, asserting that a

“charge” against her husband was “reversed” and seeking the same with respect to her conviction.

The court found it lacked jurisdiction to consider a motion to withdraw defendant’s guilty plea as

more than 30 days had passed since her guilty plea and sentencing.

¶6 In September 2022, defendant filed a pro se postconviction petition pursuant to the

Post-Conviction Hearing Act (Act) (725 ILCS 5/122-1 et seq. (West 2022)), and despite never

having previously initiated any postconviction proceedings, a motion for leave to file a successive

postconviction petition (id. § 122-1(f)). She sought to challenge her conviction based on “new

evidence” and referencing “overturned charges” in her husband’s case.

¶7 In October 2022, the trial court conducted a hearing in the matter. It noted defendant

had “completed her conditional discharge” sentence in the case. The court also found defendant’s

postconviction filings were “outside the [two-year] statute of limitations” and, as a result, it had

“lost jurisdiction” over defendant’s case.

¶8 This appeal followed.

¶9 II. ANALYSIS

¶ 10 As stated, OSAD has moved to withdraw as appellate counsel on the basis that any

-2- appeal by defendant is without arguable merit. In particular, OSAD argues a first-stage dismissal

of defendant’s pro se postconviction petition was appropriate because, following the completion

of her sentence, she lacked standing to seek relief under the Act. This court granted defendant

leave to file a response to OSAD’s motion, but she did not respond. For the reasons that follow,

we agree that defendant’s appeal lacks any arguable merit, although not for the reason articulated

by OSAD.

¶ 11 “The Act provides a method by which ‘any person imprisoned in the penitentiary’

may assert that his or her conviction was the result of a substantial denial of his or her rights under

the United States Constitution or the Illinois Constitution or both.” People v. Johnson, 2021 IL

125738, ¶ 22, 182 N.E.3d 728 (quoting 725 ILCS 5/122-1(a)(1) (West 2016)). It contemplates a

three-stage process. People v. House, 2021 IL 125124, ¶ 16, 185 N.E.3d 1234. “During the first

stage ***, the circuit court must independently review the postconviction petition, without input

from the State, and determine whether it is ‘frivolous or is patently without merit.’ ” Id. (quoting

(725 ILCS 5/122-2.1(a)(2) (West 2008)). The trial court must consider a petition’s substantive

virtue and not its procedural compliance. People v. Hatter, 2021 IL 125981, ¶ 22, 183 N.E.3d 136.

“A postconviction petition is frivolous or patently without merit if it has no arguable basis either

in law or in fact.” (Internal quotation marks omitted). Id. ¶ 23. The trial court may summarily

dismiss a petition when it meets this standard. House, 2021 IL 125124, ¶ 16. Additionally, the trial

court’s dismissal of a postconviction petition is subject to de novo review. People v. Buffer, 2019

IL 122327, ¶ 12, 137 N.E.3d 763.

¶ 12 As OSAD points out on appeal, a defendant’s statutory standing under the Act

“depends on whether he fulfilled the statutory condition of being ‘imprisoned in the penitentiary’

when he instituted the postconviction proceedings.” Johnson, 2021 IL 125738, ¶ 32. The phrase

-3- “imprisoned in the penitentiary” requires that a postconviction petitioner be someone “whose

liberty, in some way or another, was curtailed to a degree by the state.” People v. Carrera, 239 Ill.

2d 241, 246, 940 N.E.2d 1111, 1114 (2010). A defendant who has fully served his underlying

sentence before seeking postconviction relief no longer has his liberty curtailed and may not be

deemed a person “imprisoned in the penitentiary” as required by the Act. Id. at 253. Accordingly,

such defendants lack standing to file a petition for postconviction relief. Id.; see Johnson, 2021 IL

125738, ¶ 37 (“[A] petitioner loses standing to seek relief under the Act if he is no longer

‘imprisoned in the penitentiary’ because he has fully discharged his sentence for the challenged

conviction.”). Moreover, a lack of standing is an appropriate basis upon which the trial court may

summarily dismiss a postconviction petition. Id. ¶ 59.

¶ 13 Although, here, OSAD is correct with respect to its assertions of standing under the

Act, it has overlooked the fact that defendant in this case was convicted and sentenced for a

misdemeanor offense. As a result, her ability to seek postconviction relief does not stem from the

Act. Because relief under the Act is limited to persons “imprisoned in the penitentiary,” it has been

interpreted as applying only to those challenging felony convictions. People v. Shanklin, 304 Ill.

App. 3d 1056, 1058, 711 N.E.2d 796, 797 (1999) (citing People v. Davis, 54 Ill. 2d 494, 496, 298

N.E.2d 161, 163 (1973)). Rather than seeking postconviction relief under the Act, a misdemeanor

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Related

People v. Hodges
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People v. Shanklin
711 N.E.2d 796 (Appellate Court of Illinois, 1999)
People v. Wright
2013 IL App (4th) 110822 (Appellate Court of Illinois, 2013)
People v. Buffer
2019 IL 122327 (Illinois Supreme Court, 2019)
People v. Johnson
2021 IL 125738 (Illinois Supreme Court, 2021)
People v. Hatter
2021 IL 125981 (Illinois Supreme Court, 2021)
People v. House
2021 IL 125124 (Illinois Supreme Court, 2021)

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Bluebook (online)
2023 IL App (4th) 220962-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-sullivan-illappct-2023.