Williams v. Jackson

Federal 7th Circuit Court
Criminal Court
Ineffective Assistance of Counsel
Citation
Case Number: 
No. 18-2631
Decision Date: 
July 6, 2020
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

Dist. Ct. did not err in denying defendant’s habeas petition challenging his two separate rape convictions based on ground that his trial counsel was ineffective, where: (1) Illinois trial court, during Rule 402 pre-trial conference, recommended that defendant receive consecutive sentences of 20 and 21 years if he pleaded guilty to both rape cases; (2) after defendant consulted with trial counsel, trial counsel informed trial court that defendant had rejected plea offer; and (3) defendant eventually was found guilty in one rape case, but had pleaded guilty on second rape case and received consecutive sentences totaling 66 years for both cases. While defendant argued that his trial counsel was ineffective for failing to inform him of consequences of rejecting proffered 41-year plea deal and proceeding to trial, state court in defendant’s post-conviction petition could properly find that defendant failed to establish any prejudice arising out of counsel’s advice, because defendant had failed to supply any details about second rape case, so as to allow court to determine probability that he would have accepted plea offer or to determine whether defendant had received competent advice to reject plea offer.