Supreme Court Summaries
Opinions filed January 22, 2016
People v. Williams, 2016 IL 118375
Appellate citation: 2014 IL App (3) 120824
JUSTICE FREEMAN delivered the judgment of the court, with opinion.
Chief Justice Garman and Justices Thomas, Kilbride, Karmeier, Burke, and Theis concurred in the judgment and opinion.
This Tazewell County defendant was brought to trial in 2012 on a Class 2 felony charge of unlawful delivery of less than one gram of cocaine. The circuit court admonished him that, in view of his criminal record, the maximum sentence he could receive was 60 years. He negotiated with the State and pled guilty in return for a sentencing cap of 25 years, which was what he was sentenced to. Later, he moved to withdraw his guilty plea, arguing that the admonishment as to 60 years was what had induced him to agree to 25 years, and that the admonition as to 60 years was incorrect. His motion to withdraw his plea was denied by the trial court, but the appellate court reversed and remanded, saying that the motion to withdraw the guilty plea should have been granted.
In this decision, the supreme court did not agree with the appellate court’s reasoning, but did agree with the action it had taken, and its judgment was affirmed.
The dispute in this case involves the construction of the interaction of sections of both the Illinois Controlled Substances Act and the Unified Code of Corrections. The provision from the drug statute which is at issue here was enacted earlier. The supreme court said here that the competing constructions given to these statutes by both sides in this case are both reasonable, and that the earlier-enacted drug statute is now ambiguous as to what it implies about sentencing. Because it cannot be determined with certainty what the legislature intended as to the question at issue here, it is appropriate to invoke the rule of lenity, which favors the accused. The court said that the drug statute cannot be applied to double the defendant’s enhanced Class X potential maximum sentence of 30 years to reach a total of 60 years.
The motion to withdraw the guilty plea should have been granted.
The legislature is encouraged to revisit this drug provision to clarify the extent of its application.