In re H.L.
Annotate this CaseDefendant admitted the allegations of petitions to revoke his probation in two cases and admitted the allegations of a delinquency petition in a third case. He was sentenced to indefinite commitment in the Department of Juvenile Justice. He moved for reconsideration. The court denied the motion. Supreme Court Rule 604(d) governs appeal from a judgment entered upon a guilty plea and provides: “defendant’s attorney shall file with the trial court a certificate stating that the attorney has consulted with the defendant either by mail or in person to ascertain defendant’s contentions of error in the sentence or the entry of the plea of guilty, has examined the trial court file and report of proceedings of the plea of guilty, and has made any amendments to the motion necessary for adequate presentation of any defects in those proceedings.” Defense counsel filed a Rule 604(d) certificate three weeks after the motion hearing. The appellate court vacated the denial for noncompliance with the rule. The Illinois Supreme Court reversed. Strict compliance with the rule does not require counsel to file a certificate of compliance before or at the hearing on the post-plea motion, but requires counsel to prepare a certificate that meets the rule’s content requirements and to file it with the trial court before filing of any notice of appeal.
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