Illinois Appellate Court
Civil Court
Sentencing
Defendant pled guilty to home invasion and was sentenced to 12 years. Defendant challenged sentence as excessive through postsentencing motions. Case remanded, numerous times, as defendant's counsel failed to strictly comply with Rule 604(d). Statutory amendment to Rule 604(d) (removing clause limiting certification requirement to defendants moving to withdraw their guilty pleas) was procedural, as it dictated practices to be followed by defense attorneys in filing postplea motions, and thus should be applied retroactively. For Defendant to receive a full and fair hearing on his postplea motion, defense counsel must file a complaint Rule 604(d) certificate. (CARTER, concurring; SCHMIDT, dissenting.)