Illinois Appellate Court
Criminal Court
Post-Plea Proceedings
Defendant pled guilty to possession with the intent to deliver methamphetamine and was sentenced to 10 years in prison. On appeal, defendant argued that he was denied the effective assistance of counsel because trial court had a conflict of interest during post-plea proceedings, that defense counsel failed to comply with SCR 604(d), and that the trial court failed to comply with SCR 45. The appellate court vacated the circuit court’s judgment regarding SCR 604(d) compliance and remanded, finding that while there was a facially valid 604(d) certificate, the record established that counsel did not actually fulfill her obligations under the rule. (HARRIS and STEIGMANN, concurring)