People v. Milian

Defendant entered a blind guilty plea to attempted 1st degree murder, and was sentenced to 22 years. Defense counsel filed a motion to reconsider sentence which was denied in March 2015. The appellate court held that the March 2016 amendment to Rule 604(d) applied retroactively to defense counsel's certificate, and was thus deficient as it did not state that counsel examined the report of proceedings for sentencing hearing, as the amended rule required.In order to adequately consider all potential errors in the sentence, defense counsel needed to examine the report of proceedings for the sentencing hearing. The certificate did not indicate that counsel had done so, and thus the certificate does not serve as a guarantee of compliance with Rule 604(d)'s imperatives. Thus, remanded for new postplea proceedings. (O'BRIEN, concurring; SCHMIDT, specially concurring.)