People v. Hudson
95 N.E.3d 1148
| Ill. App. Ct. | 2017Background
- In 2004 Robert Hudson was indicted for armed robbery (Class X) and three counts of unlawful restraint; his public defender interviewed him and later received a LEADS criminal-history report showing multiple prior convictions and alias use that would trigger habitual-offender mandatory life if proven.
- Defense counsel misinformed Hudson about his exposure (told him an extended term of 6–60 years and later estimated 44 years), and Hudson rejected multiple plea offers from the State, including a 16-year offer made while the jury deliberated.
- A jury convicted Hudson; a presentence investigation revealed two prior Class X convictions, making the armed-robbery conviction Hudson’s third Class X and subjecting him to mandatory natural life; Hudson was sentenced to life without parole.
- State and Illinois courts initially rejected Hudson’s ineffective-assistance claims; meanwhile Hudson pursued federal habeas relief, and the federal district court granted relief, finding counsel ineffective during plea negotiations and directing the State to reoffer a plea that would not trigger mandatory life (a 20-year offer to attempted armed robbery, a Class 1 felony).
- Hudson accepted the reoffered 20-year plea, but the state trial court (on remand) refused to accept the plea and maintained the convictions and life sentence; Hudson appealed the trial court’s rejection of the reoffered plea.
- The Illinois Appellate Court (3d Dist.) reversed, holding that under Lafler the trial court’s discretion was limited by the need to neutralize the Sixth Amendment taint and that rejecting a plea to a charge that would avoid mandatory life was improper; the matter was remanded with directions to accept the Class 1 plea and resentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the state trial court properly rejected the State’s reoffer of a 20‑year plea (to a charge not triggering mandatory life) after federal habeas found ineffective assistance during plea negotiations | State: trial court properly exercised its discretion under Lafler to accept or reject plea offers | Hudson: trial court must accept the plea (or otherwise neutralize the Sixth Amendment taint); acceptance was required to remedy the constitutional violation | The appellate court held the trial court abused its discretion by rejecting a plea to a charge that would avoid mandatory life; directed acceptance and resentencing |
| Proper standard of review for trial court’s remedy decision | State: abuse of discretion (trial court rejecting plea) | Hudson: de novo | Court applied abuse-of-discretion review but emphasized Lafler limits that discretion |
| Scope of the remedy required after counsel’s ineffective assistance in plea negotiations | State: trial court may tailor remedy, including rejection or modification | Hudson: remedy must neutralize taint and restore parties to pre-offer positions as much as possible | Remedy must be tailored to neutralize the taint; here that required accepting a plea that did not trigger mandatory life |
| Whether resentencing alone could cure the prejudice from ineffective plea advice where a mandatory sentence constrained sentencing discretion | State: resentencing could be an option | Hudson: resentencing on convictions would not suffice because mandatory life would remain | Court agreed resentencing alone was inadequate and accepted the federal court’s approach to reoffer a plea to a non‑life‑triggering charge |
Key Cases Cited
- Lafler v. Cooper, 566 U.S. 156 (Sup. Ct.) (framework for remedies when ineffective assistance during plea negotiations prejudices defendant)
- Hudson v. Lashbrook, 863 F.3d 652 (7th Cir. 2017) (appellate disposition of federal habeas enforcement; affirms habeas court’s ineffective-assistance ruling)
- People v. Curry, 178 Ill.2d 509 (Ill.) (defendant’s right to be informed of direct consequences of plea; remedy must neutralize constitutional taint)
- People v. Henderson, 211 Ill.2d 90 (Ill.) (standard on trial court discretion to accept or reject plea agreements)