Background
Jason W. Haltom was charged with two counts of domestic battery arising from allegations that he struck J.H. in the face with his hand. Following an August 25, 2025, bench trial, the circuit court found him guilty on both counts, merged the second count into the first, and sentenced him to 12 months’ conditional discharge.
On September 23, 2025, Haltom filed a pro se motion under People v. Krankel alleging ineffective assistance of trial counsel. Among other claims, he alleged that counsel failed to discuss the case with him until the day of trial, review the evidence with him before trial, and use J.H.’s prior allegedly false 911 calls to establish her psychosis. After conducting an initial inquiry, the circuit court declined to appoint independent counsel on October 24, 2025. Haltom filed his notice of appeal on November 21, 2025.
The Court’s Holding
The appellate court dismissed the appeal for lack of jurisdiction because Haltom filed his notice of appeal more than 30 days after the August 25, 2025, final judgment. It held that his pro se Krankel motion did not qualify as a motion directed against the judgment that would toll the appeal deadline under Illinois Supreme Court Rule 606(b).
The court explained that a pro se posttrial claim alleging ineffective assistance is a common-law Krankel remedy, not a statutory motion for a new trial under section 116-1 of the Code of Criminal Procedure. Reading Illinois Supreme Court precedent and Rule 606(b) together, the court concluded that a Krankel motion is not a qualifying posttrial or postsentencing motion for purposes of either the rule’s premature-appeal provision or its tolling provision. Haltom’s November notice therefore was untimely.
Key Takeaways
- A criminal defendant generally must file a notice of appeal within 30 days after entry of the final judgment unless a qualifying motion directed against the judgment is timely filed.
- A pro se Krankel motion alleging ineffective assistance of trial counsel does not toll the Rule 606(b) deadline for filing a notice of appeal.
- Because a timely notice of appeal is required to confer appellate jurisdiction, the court could not reach Haltom’s substantive appellate arguments.
Why It Matters
The order draws a consequential procedural distinction between a Krankel motion and a statutory posttrial motion directed against the judgment. Defendants who pursue Krankel claims must still independently protect the deadline for appealing the underlying criminal judgment.
The decision was issued under Illinois Supreme Court Rule 23(b) and is nonprecedential except in the limited circumstances permitted by Rule 23(e)(1).