People v. Hale, 996 N.E.2d 607

Hale challenges trial counsel's effectiveness during plea negotiations for allegedly failing to inform him that consecutive sentences were mandatory if convicted on both counts.
Circuit court rejected the ineffective assistance claim; the appellate court reversed, citing Strickland prejudice due to counsel's failure to inform about mandatory consecutive terms.
Evidence at trial showed Hale fired approximately eight shots at a vehicle, injuring Booker and nearly killing Tankson; witnesses identified Hale as the shooter.
Sentencing included mandatory consecutive terms under section 5-8-4, with certain counts merged; Hale received 30 years for one attempt count and 10 years for the other, consecutive to each other.
Hale pursued Krankel proceedings; pro se motions alleged ineffective assistance during plea negotiations, leading to an evidentiary hearing where testimony about a 15-year plea offer and sentencing expectations was presented, and trial counsel acknowledged discussions about sentencing.
This court analyzes whether Hale demonstrated prejudice under Frye/Cooper, concluding Hale failed to show a reasonable probability he would have accepted the 15-year offer but for counsel's alleged error; thus, no Strickland prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hale proved prejudice from counsel's alleged failure to inform about mandatory consecutive sentences.	Hale argues counsel's advice prevented a knowing, voluntary decision and would have accepted the offer if properly advised.	Urban contends Hale would not have accepted the offer regardless, and there was no prejudice.	No prejudice shown; appellate reversal reversed; circuit court affirmed.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong standard for ineffective assistance)
Curry, 178 Ill. 2d 509 (Ill. 1997) (right to be reasonably informed of direct consequences during plea negotiations)
Krankel, 102 Ill. 2d 181 (Ill. 1984) (limited Krankel procedure for ineffectiveness claims)
Moore, 207 Ill. 2d 68 (Ill. 2003) (limited remand for Krankel evaluation)
Frye, 132 S. Ct. 1399 (U.S. 2012) (prejudice requires showing would have accepted plea, plus probability of better outcome)
Lafler v. Cooper, 132 S. Ct. 1376 (U.S. 2012) (prejudice factors when plea offers are rejected due to ineffective assistance)
Wagener, 196 Ill. 2d 269 (Ill. 2001) (doctrine interpreting federal precedent in Illinois context)
People v. Curry, 178 Ill. 2d 509 (Ill. 1997) (see Curry for pleading-informed rights and prejudice framework)