People v. Boykins, 93 N.E.3d 504

Byron Boykins (age 20 at plea) pled guilty in 2009 to first-degree murder pursuant to a negotiated plea: 22 years’ imprisonment, dismissal of other charges.
At the plea hearing the court advised the statutory sentencing range for murder (20–60 years, up to life in certain circumstances) and stated: “Upon your release from the penitentiary, there is a period of three years mandatory supervised release.”
The court accepted the plea, waived a presentence investigation, and imposed the agreed 22‑year term; the court did not mention MSR at sentencing and the written judgment did not reference MSR.
In 2014 Boykins filed a pro se postconviction petition claiming his due process rights were violated because the court failed to link the mandatory 3‑year MSR to his bargained‑for 22‑year sentence, depriving him of the benefit of his plea bargain.
The circuit court summarily dismissed the petition; the appellate court affirmed. The Illinois Supreme Court granted leave and affirmed the appellate court, holding the plea admonishments satisfied due process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court’s plea admonishments satisfied due process by informing Boykins that a 3‑year MSR would be added to his negotiated 22‑year term	Boykins: plea did not adequately link MSR to the agreed 22‑year sentence; he understood his total penalty to be 22 years and therefore received a harsher sentence than bargained for	State/Respondent: court advised the range for murder and expressly told Boykins that any release from prison would be followed by a 3‑year MSR; an ordinary person would understand MSR would follow the negotiated prison term	Court: admonishment was sufficient under Rule 402 and Whitfield/Morris standards; record refutes Boykins’ claim and summary dismissal was proper

People v. Whitfield, 217 Ill.2d 177 (2005) (requires defendants entering negotiated pleas be advised that a term of MSR will be added to the agreed sentence)
People v. Morris, 236 Ill.2d 345 (2010) (clarifies MSR admonition must convey that MSR will be added to the agreed sentence; admonition judged by whether an ordinary person would understand it)
People v. Hodges, 234 Ill.2d 1 (2009) (standard for summary dismissal of postconviction petitions: frivolous or patently without merit)
People v. Williams, 97 Ill.2d 252 (1983) (articulates objective standard: admonition suffices if an ordinary person in the defendant’s circumstances would understand it)
United States ex rel. Miller v. McGinnis, 774 F.2d 819 (7th Cir. 1985) (Seventh Circuit decision finding due process violation where defendant was told a 20‑year maximum but not told of additional MSR; distinguished on its facts)