In re H.L., 48 N.E.3d 1071

Respondent H.L., a juvenile, admitted allegations in multiple cases and was committed to the Department of Juvenile Justice; he filed a postplea motion to reconsider sentence which the trial court denied.
Trial counsel filed a Rule 604(d) attorney certificate with the trial court about three weeks after the hearing on the motion and then filed a notice of appeal.
The appellate court held counsel’s certificate had to be filed at or before the hearing (relying on People v. Shirley), vacated the denial, and remanded for a new hearing and a new certificate filed at or before that hearing.
The State appealed to the Illinois Supreme Court, which granted leave to resolve whether Rule 604(d)’s certificate must be filed at or before the postplea-motion hearing.
The Supreme Court reversed the appellate court, holding Rule 604(d) requires strict compliance but does not impose a timing requirement that the certificate be filed prior to or at the hearing; it only must be filed with the trial court (i.e., before any notice of appeal).
The Supreme Court remanded to the appellate court to consider other issues it had not reached; Justice Freeman dissented, arguing Shirley had required filing before or at the hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 604(d)’s attorney certificate must be filed at or before the postplea-motion hearing	State: rule has no timing requirement beyond filing “with the trial court”; filing while court had jurisdiction complies	H.L.: Shirley and other authority require certificate before or at the hearing to ensure trial court can consider counsel’s review and amendments	The court held strict compliance requires filing a proper certificate with the trial court (i.e., not on appeal and before notice of appeal) but does not mandate filing prior to or at the hearing
Remedy when certificate not filed or deficient	State: remand may be unnecessary if harmless	H.L.: remand required for new motion/hearing to achieve strict compliance	Court reaffirmed remand is remedy for noncompliance but rejected automatic requirement of filing before/at hearing as a basis for further remands

People v. Shirley, 181 Ill. 2d 359 (1998) (discusses strict compliance and states certificate "should precede or be simultaneous with" hearing but does not expressly mandate timing)
People v. Janes, 158 Ill. 2d 27 (1994) (remand remedy where Rule 604(d) requirements were not strictly complied with)
People v. Janes, 168 Ill. 2d 382 (1995) (addresses belated affidavit and explains Rule 604(d) filing should precede motion)
People v. Wilk, 124 Ill. 2d 93 (1988) (explains Rule 604(d) purpose: permit fact-finding in trial court before appeal)