People v. English, 226 N.E.3d 1204

Johnny English, an incarcerated pro se litigant, filed a motion for leave to file a successive postconviction petition; the trial court denied it on August 3, 2020.
A notice of appeal was due within 30 days (by September 2, 2020); the circuit clerk’s file stamp shows September 10, 2020, but the mailed envelope bore a postage meter stamp dated September 1, 2020.
English included a signed “Notice of Mailing/Filing” identifying the mailing and recipients but did not submit a certification under section 1-109 (the Rule 12(b)(6) certification required for incarcerated pro se mailings).
The appellate court dismissed the appeal for lack of jurisdiction, concluding the postage meter stamp alone did not satisfy Rules 373 and 12 proof-of-mailing requirements.
The Illinois Supreme Court affirmed, holding that for an incarcerated, self-represented litigant the exclusive method to establish the “time of mailing” under Rule 373 is the Rule 12(b)(6)/section 1-109 certification; absent it, the notice was untimely.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a postage meter stamp (or postmark) is sufficient proof of the "time of mailing" under Ill. S. Ct. R. 373 for an incarcerated pro se litigant	English: the postage meter stamp on the envelope (and undisputed mailing date) proves timely mailing and should satisfy Rule 373	State: stamp alone is insufficient; Rule 373 requires proof as provided in Rule 12 (certification/affidavit)	Held: stamp not sufficient; incarcerated pro se litigant must use Rule 12(b)(6)/§1-109 certification to prove time of mailing
Whether Rules 373 and 12 permit other forms of proof (postmark/meter stamp) instead of the specified certification/affidavit	English: equity and undisputed third-party date justify accepting the meter stamp as proof	State: rules are unambiguous and mandatory; no exceptions may be grafted in	Held: Rules are plain and mandatory; courts may not add exceptions—certification is the sole method
Whether equitable relief or appellate remedies should save the appeal despite the procedural defect	English: strict enforcement frustrates access to justice where mailing date is undisputed	State: appellant/counsel could have sought relief under Rule 606(c) or other motions; rules must be enforced	Held: appellate remedies exist but were not pursued; nevertheless, failure to comply with Rule 12(b)(6) bars jurisdiction and dismissal is affirmed

Secura Insurance Co. v. Illinois Farmers Insurance Co., 232 Ill. 2d 209 (requiring Rule 12 proof of mailing to invoke mailbox rule)
People v. Lugo, 391 Ill. App. 3d 995 (Ill. App. 2009) (postmark alone cannot substitute for certificate/affidavit under Rule 12)
People v. Molnar, 222 Ill. 2d 495 (administrative mailing regulations incorporated into law)
People v. Glasper, 234 Ill. 2d 173 (supreme court rule violations often reviewed for harmless error or substantial compliance)
Wickman v. Illinois Property Tax Appeal Board, 387 Ill. App. 3d 414 (definition and discussion of postmark)