People v. Akins, 2016 IL App (4th) 150539

Defendant Kevin Akins was charged with four drug counts (two possession with intent to deliver; two delivery) arising from controlled buys in October 2013; he was already serving an 8-year sentence in another case.
In April 2014 Akins pleaded guilty to one delivery count (count III) in exchange for dismissal of remaining counts and an agreed 8-year extended-term sentence to run consecutively to his existing sentence.
Defense counsel (APD Stephanie Corum) repeatedly communicated plea offers, case evidence, sentencing ranges, and strategy to Akins by phone and detailed letters; she provided a photograph taken from police surveillance and discussed the State’s strongest evidence (surveillance video and officer testimony).
Akins later moved to withdraw his plea, claiming ineffective assistance because counsel did not show him the full surveillance recording, rushed him into accepting the plea, failed to file a motion to disclose the confidential source, and provided only a still image (exhibit No. 3) rather than the full video.
After hearings in Sept. 2014 and June 2015, the trial court denied the motion, finding the plea knowing and voluntary and rejecting claims that Akins was rushed or that counsel performed deficiently. Akins appealed; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel rendered ineffective assistance by failing to show/discuss the full surveillance recording before advising plea	The State argued counsel adequately informed defendant of evidence, options, and consequences; counsel’s conduct was reasonable and detailed; no Strickland prejudice shown	Akins argued counsel had a constitutional duty to present and discuss all relevant evidence (including full surveillance) supporting the plea recommendation; without it he would not have pled	Court held counsel’s performance was not deficient: she reasonably informed Akins via letters, calls, and a still photo; no reasonable probability he would have insisted on trial; plea was knowing and voluntary
Whether the plea was involuntary/incorrectly induced by pressure or a rushed decision	The State showed multiple communications and time (months) to consider offers and that offers changed by negotiation; defendant had options explained	Akins claimed he was rushed at the April hearing, had only seconds with counsel, and felt coerced into accepting the 8-year offer	Court found defendant was not rushed or coerced; he had been informed of risks and alternatives over time; trial court did not abuse discretion in denying withdrawal

Strickland v. Washington, 466 U.S. 668 (ineffective-assistance two-part test)
People v. Cloutier, 191 Ill. 2d 392 (reasonableness of counsel’s investigation; deference to strategy)
People v. Clendenin, 238 Ill. 2d 302 (failure to show either Strickland prong is fatal)
People v. Hughes, 2012 IL 112817 (manifest injustice standard for plea withdrawal)