People v. Sykes

2025 IL App (1st) 240188-U
CourtAppellate Court of Illinois
DecidedJune 18, 2025
Docket1-24-0188
StatusUnpublished

This text of 2025 IL App (1st) 240188-U (People v. Sykes) 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. Sykes, 2025 IL App (1st) 240188-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 240188-U Order filed: June 18, 2025

FIRST DISTRICT FOURTH DIVISION

No. 1-24-0188

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent 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. 09 CR 10667 ) LAWRENCE SYKES, ) Honorable ) Domenica A. Stephenson, Defendant-Appellant. ) Judge, presiding. ______________________________________________________________________________

PRESIDING JUSTICE ROCHFORD delivered the judgment of the court. Justices Lyle and Ocasio concurred in the judgment.

ORDER

¶1 Held: The summary dismissal of defendant’s postconviction petition at the first stage is affirmed, where claims raised on appeal were not raised in defendant’s pro se postconviction petition.

¶2 Defendant-appellant, Lawrence Sykes, appeals from the first-stage dismissal of the

postconviction petition he filed pursuant to the Post-Conviction Hearing Act (Act) (725 ILCS

5/122-1 et seq. (West 2022)). For the following reasons, we affirm.

¶3 The trial proceedings and the evidence presented at trial were fully set out in our prior

order, entered upon defendant’s direct appeal, and need not be fully restated here. See People v.

Sykes, 2015 IL App (1st) 130070-U. We therefore restate only those facts necessary to resolve this

appeal, with portions of this order taken from our prior decision. No. 1-24-0188

¶4 Defendant’s conviction arose from a May 15, 2009, altercation which resulted in the

stabbing death of Clemon Webb. Prior to trial, defendant’s trial counsel filed a motion for a fitness

hearing which attached an evaluation from clinical neuropsychologist Dr. Robert Hanlon, an

associate professor of psychiatry and neurology at Northwestern University Feinberg School of

Medicine. As set forth in his evaluation, Dr. Hanlon concluded defendant was not fit to stand trial

due to dementia caused by drug and alcohol abuse, schizophrenic-spectrum disorder, and low

intellectual functioning. However, two State experts later determined that defendant was fit to

stand trial. Trial counsel subsequently filed a motion to withdraw the motion for a fitness hearing,

which attached a later evaluation from Dr. Hanlon which set forth his findings that defendant’s

medication had been adjusted, and that he was now fit to stand trial.

¶5 Nevertheless, the trial court held a fitness hearing because defense counsel previously had

a bona fide doubt as to defendant’s fitness. At the hearing, the parties proceeded by way of

stipulation as to the testimony of their respective experts. Ultimately, the trial court found

defendant was fit to stand trial.

¶6 Following a bench trial, defendant was convicted of first-degree murder and sentenced to

32 years’ imprisonment. On direct appeal, defendant contended that: (1) trial counsel was

ineffective for failing to argue that evidence purporting to show the victim’s aggressive nature was

admissible under People v. Lynch, 104 Ill. 2d 194 (1984); (2) his sentence was excessive, and (3)

the trial court imposed certain improper pecuniary fines and fees and granted insufficient

presentencing credit. Sykes, 2015 IL App (1st) 130070-U, ¶ 2. In an order entered in May 2015,

this court affirmed defendant’s conviction and sentence, vacated certain fees, and granted

defendant additional credit for presentence custody against imposed fines. Id. ¶¶ 2, 53.

-2- No. 1-24-0188

¶7 Defendant filed the instant pro se petition for postconviction relief on October 6, 2023. His

petition alleged that (1) he was currently unfit to proceed in the instant proceedings due to taking

various medications, (2) he was unfit to stand trial, (3) his trial counsel was ineffective for failing

to request a second fitness hearing after he received certain prescription medications, and (4) his

appellate counsel was ineffective for failing to claim on appeal that defendant was not fit for trial,

that defendant’s rights were violated by the trial court’s failure to conduct a fitness hearing because

defendant was on psychotropic medications, and/or defendant’s rights were violated by the trial

court’s failure to enforce the statute governing reports for fitness determinations. Defendant

attached an affidavit in which he attested that he had a long history of psychiatric hospitalizations

for several psychiatric disorders, he was unable to state where he was in 2009 or what he was doing

at the time of the crime, and that he could not describe the defense his attorney raised at trial.

¶8 On January 2, 2024, the circuit court summarily dismissed defendant’s petition in a written

order finding its claims frivolous and patently without merit. With regards to defendant’s claims

that he was unfit to stand trial, the court found that they were subject to procedural default because

they could have been raised in the appellate court. Beyond forfeiture, the court addressed and

rejected the merits of defendant’s unfitness claim. Defendant thereafter filed a timely notice of

appeal.

¶9 The Act provides a procedural mechanism through which a defendant may assert that his

conviction or sentence resulted from a substantial denial of his constitutional rights. 725 ILCS

5/122-1 (West 2022). The Act provides a three-stage process for adjudication of a postconviction

petition. People v. Applewhite, 2020 IL App (1st) 142330-B, ¶ 15. At the first stage of a

postconviction proceeding, the postconviction court must assess the petition, taking the allegations

as true, and determine if it is frivolous or patently without merit such that it failed to state the gist

-3- No. 1-24-0188

of a meritorious constitutional claim. Id.; People v. Hodges, 234 Ill. 2d 1, 10 (2009). A petition

may be summarily dismissed as frivolous or patently without merit only if the petition has no

arguable basis in either fact or law. People v. Tate, 2012 IL 112214, ¶ 9 (“the threshold for survival

[is] low”). A petition lacks an arguable basis in fact or law when it “is based on an indisputably

meritless legal theory or a fanciful factual allegation.” Hodges, 234 Ill. 2d at 16. Fanciful factual

allegations are those which are “fantastic or delusional” and an indisputably meritless legal theory

is one that is “completely contradicted by the record.” Id. at 16-17. Our review of a first-stage

summary dismissal is de novo. Tate, 2012 IL 112214, ¶ 10.

¶ 10 On appeal, defendant contends that his pro se post-conviction petition was improperly

dismissed at the first-stage where it “stated the gist of a constitutional claim that he received

ineffective assistance of counsel at his fitness hearing where trial counsel unreasonably stipulated

to the State’s summary of its psychologist’s report and failed to call the defense psychologist to

testify, and where the trial court arguably would have found defendant unfit but for counsel’s

deficiencies.” However, in his briefs filed on appeal defendant also concedes that his pro se

petition only alleged—in relevant part—“that his trial counsel failed to protect his right to not be

tried while unfit by failing to initiate a second fitness hearing to address his fitness while taking

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Related

People v. Vilces
748 N.E.2d 1219 (Appellate Court of Illinois, 2001)
People v. Hodges
912 N.E.2d 1204 (Illinois Supreme Court, 2009)
People v. Lynch
470 N.E.2d 1018 (Illinois Supreme Court, 1984)
People v. Jones
821 N.E.2d 1093 (Illinois Supreme Court, 2004)
People v. Thomas
2014 IL App (2d) 121001 (Appellate Court of Illinois, 2014)
People v. Reed
2014 IL App (1st) 122610 (Appellate Court of Illinois, 2015)
People v. Tate
2012 IL 112214 (Illinois Supreme Court, 2012)
People v. Cole
2012 IL App (1st) 102499 (Appellate Court of Illinois, 2012)
People v. Applewhite
2020 IL App (1st) 142330-B (Appellate Court of Illinois, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
2025 IL App (1st) 240188-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-sykes-illappct-2025.