People v. Arriaga, 2023 IL App (5th) 220076

Defendant (Arriaga) entered negotiated guilty pleas to two counts and was sentenced per agreement; court admonished that any motion to withdraw plea must be filed in writing within 30 days of judgment.
Defendant sent multiple pro se letters dated within 30 days claiming intoxication, mental-health issues, and requesting withdrawal; the letters were file-stamped much later (first file-stamp relevant to the withdrawal request: August 11, 2021).
The trial court treated the letters as a pro se motion to withdraw plea, appointed new counsel because of ineffective-assistance allegations, and postplea counsel filed an amended petition and Rule 604(d) certificate.
After a hearing, the trial court denied the motion to withdraw plea; defendant appealed.
The central legal dispute on appeal was whether the trial court had jurisdiction to decide the pro se motion because it was not filed within 30 days and defendant failed to provide the section 1-109 certification required to invoke the mailbox rule (Ill. S. Ct. R. 373 and R. 12(b)(6)).
The appellate court concluded the pro se motion was file-stamped more than 30 days after judgment (44 days), defendant did not attach a section 1-109 certification, and therefore the trial court lacked jurisdiction; the denial was vacated and the motion ordered dismissed for lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had jurisdiction to consider the pro se motion to withdraw plea because it was filed more than 30 days after judgment and lacked mailbox-rule proof	The State: without a timely filing or a proper section 1-109 certification to invoke the mailbox rule, the trial court lost jurisdiction	Arriaga: his dated letters show he mailed them within 30 days; request remand so he can supply certification	Court: No jurisdiction. Because no section 1-109 certification, use file-stamp (August 11) → motion filed after 30 days → vacate and dismiss for lack of jurisdiction
Whether appellate court should remand to allow supplementation with a section 1-109 certification (relying on People v. Cooper)	The State: remand inappropriate because trial court never had jurisdiction; dismissal is required	Arriaga: asks remand to prove timely mailing since his letters were dated within 30 days	Court: Declined remand. Cooper was viewed as overbroad; appellate precedent and Supreme Court rules do not permit post-hoc supplementation to cure lack of required certification
Whether pro se status excuses noncompliance with filing/certification requirements	The State: rules must be followed; pro se status does not excuse defects	Arriaga: implicit reliance on pro se status and mailing dates to justify leniency	Court: Pro se status does not excuse noncompliance; litigants are presumed to know procedural rules

People ex rel. Alvarez v. Skryd, 241 Ill. 2d 34 (Ill. 2011) (subject-matter jurisdiction limits a trial court's power to modify judgments)
People v. Bailey, 2014 IL 115459 (Ill. 2014) (appellate review limited to jurisdictional issue where trial court lacked jurisdiction; vacate and dismiss if so)
Secura Insurance Co. v. Illinois Farmers Insurance Co., 232 Ill. 2d 209 (Ill. 2009) (appellate court cannot excuse noncompliance with supreme court rules)
Steinbrecher v. Steinbrecher, 197 Ill. 2d 514 (Ill. 2001) (pro se litigants are not entitled to more lenient standards for procedural compliance)
People v. Tlatenchi, 391 Ill. App. 3d 705 (Ill. App. 2009) (discussing Rule 373 mailbox rule and section 1-109 certification)
People v. Lugo, 391 Ill. App. 3d 995 (Ill. App. 2009) (absence of Rule 12(b) certificate bars reliance on Rule 373)
Ingrassia v. Ingrassia, 156 Ill. App. 3d 483 (Ill. App. 1987) (proof of service by mail must substantially comply with Rule 12)
People v. Flowers, 208 Ill. 2d 291 (Ill. 2003) (appellate court's powers are limited compared to Supreme Court supervisory authority)
People v. Adams, 318 Ill. App. 3d 539 (Ill. App. 2001) (pro se litigants must comply with procedural rules)