People v. Suaste-Gonzalez

Defendant appealed from the trial court’s denial of his post-plea motion seeking to withdraw his guilty plea, arguing that post-plea counsel’s Rule 604(d) certificate was filed before counsel had obtained or read the report of proceedings and that the post-plea counsel was ineffective for failing to file a motion to reconsider defendant’s sentence. The appellate court vacated and remanded, finding that based on the timing of the filings and the substance of counsel’s filings the trial court failed to strictly comply with Rule 604(d). (McLAREN and SCHOSTOK, concurring)