People v. Zimmerman

Illinois Appellate Court
Criminal Court
Relief from Judgment
Citation
Case Number: 
2016 IL App (2d) 130350
Decision Date: 
Wednesday, January 13, 2016
District: 
2d Dist.
Division/County: 
Lake Co.
Holding: 
Vacated and remanded.
Justice: 
JORGENSEN

Defendant was convicted of armed violence in 2010. Defendant filed petition for relief form judgment under Section 2-1401.  Absent a specific motion, responsive pleading, or explicit statement of waiver of service, State does not waive objection to improper service.  Allowing State's presence in court to amount to a waiver of service would contradict the purpose of removing the general-appearance provision from Section 2-301.  Court prematurely dismissed Section 2-1401 petition, as petition was not properly served.  (Defendant had asked court to waive requirement that he serve State's Attorney by certified mail, as he was indigent; State filed no formal appearance or response to petition.  State appeared in court but was silent.)(SCHOSTOK and BIRKETT, concurring.)