People v. Addison
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Addison was convicted, in absentia, of unlawful possession of a motor vehicle, unlawful possession of a converted motor vehicle, forgery, and two counts of theft, arising out of his alleged use of counterfeit money to purchase a motorcycle, and was sentenced to 15 years’ imprisonment. Having failed to appear for trial, he was subsequently arrested.
Addison’s appellate counsel did not file a brief and determined that there are no meritorious issues, except concerning credit that should be applied toward the prison sentences. Addison filed a postconviction petition, contending that trial and appellate counsel were deficient. Appointed postconviction counsel filed an amended petition, alleging trial counsel was ineffective for failing to file a motion to suppress based on improper Miranda warnings, for failing to object to expert testimony regarding counterfeit currency when no expert was disclosed, and for failing to argue sufficiency of the evidence where there were discrepancies; and that the court erred in giving an accountability instruction. The petition did not assert ineffective assistance of appellate counsel. The trial court dismissed the petition.
Addison appealed, arguing that postconviction counsel rendered unreasonable assistance in failing to argue ineffective assistance of appellate counsel. The Illinois Supreme Court agreed. Addison did not forfeit collateral review of his conviction by failing to appear at trial. While any postconviction claims that could have been raised on direct appeal are generally forfeited that forfeiture could have been overcome by framing the issues as ineffective assistance of appellate counsel for failing to raise the issues on direct appeal. The appellate court properly remanded for compliance with Illinois Supreme Court Rule 651(c) without considering the merits.
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