Background
Chauncy D. Lucas Jr. entered a fully negotiated guilty plea to intentional first degree murder in Madison County. The State amended the charge to allege that Lucas bludgeoned Tyrone Williams in the chest, causing his death. In exchange for the plea, Lucas received 30 years in prison, to be served at 100%, followed by three years of mandatory supervised release; the other murder count was dismissed.
At the March 18, 2025 plea and sentencing hearing, the circuit court advised Lucas that he had to file a written motion to withdraw his plea within 30 days before pursuing an appeal. More than four months later, Lucas filed a pro se motion to withdraw his plea, alleging coercion, ineffective assistance, self-defense evidence, and an impaired state of mind. The circuit court dismissed the motion as untimely.
The Court’s Holding
The Illinois Appellate Court, Fifth District, held that the circuit court correctly dismissed Lucas’s motion for lack of jurisdiction. Under Illinois Supreme Court Rule 604(d), a defendant seeking to appeal from a fully negotiated guilty plea must file a motion to withdraw the plea and vacate the judgment within 30 days after sentencing. Lucas filed his motion after that deadline.
The court also found that the circuit court had substantially complied with the required Rule 605(c) appeal admonitions, so the admonition exception did not apply. Because no nonfrivolous argument could challenge the dismissal, the court granted the Office of the State Appellate Defender leave to withdraw under Anders v. California and dismissed the appeal.
Key Takeaways
- A motion to withdraw a guilty plea under Rule 604(d) must be filed within 30 days after sentencing.
- After that period, the circuit court lacks jurisdiction to consider the motion and must dismiss it.
- Substantial compliance with Rule 605(c) admonitions forecloses an exception based on inadequate appeal instructions.
Why It Matters
The decision reinforces the jurisdictional consequence of missing Rule 604(d)’s 30-day filing deadline after a negotiated guilty plea. Defendants who receive proper post-plea admonitions cannot obtain appellate review through a later-filed withdrawal motion.
This Rule 23 order is nonprecedential except in the limited circumstances allowed by Illinois Supreme Court Rule 23(e)(1).