People v. Williams

Illinois Appellate Court
Criminal Court
Plain Error Review
Citation
Case Number: 
2025 IL App (1st) 230584-B
Decision Date: 
Friday, May 30, 2025
District: 
1st Dist.
Division/County: 
5th Div./Cook Co.
Holding: 
Affirmed.
Justice: 
MIKVA

Defendant was convicted of vehicular hijacking with a firearm and was sentenced to 30 years in prison. On appeal, defendant argued that the trial court failed to properly admonish him pursuant to SCR 401(a). The appellate court initially reversed the trial court but the Illinois Supreme Court issued a supervisory order instructing the court to consider the effect of a recent case to determine whether the failure to properly admonish under Rule 401(a) is reviewable as second prong error. The appellate court concluded that defendant’s claim was not cognizable as plain error and affirmed his conviction on appeal. (MITCHELL and LYLE, concurring)