People v. Brown

Defendant pled guilty to aggravated domestic battery and was sentenced to three years in prison. He moved to withdraw his plea and vacate his sentence on the basis that was denied the effective assistance of counsel. The trial court appointed new counsel and ultimately denied defendant’s motion. Defendant appealed, arguing that post-plea counsel failed to comply with SCR 604(d). The appellate court affirmed, finding that even though the Rule 604(d) certificate did not strictly comply with the rule, remand was unwarranted under the circumstances of the case because defendant had received a full and fair hearing that determined his claims were without merit. (TURNER and LANNERD, concurring)