2025 IL App (4th) 220887
Ill. App. Ct.2025Background
- Raymond A. Maury III was stopped by Illinois State Police in 2018, charged with possession with intent to deliver over 400 grams of cocaine and possession of heroin.
- Multiple motions to suppress evidence from the traffic stop were filed (pro se and by various attorneys), all denied by the trial court.
- In 2022, Maury was convicted at trial of unlawful possession with intent to deliver cocaine and sentenced to 35 years in prison.
- Maury appealed, arguing ineffective assistance of counsel, improper denial of new counsel (per People v. Krankel), errors in evidentiary rulings, and that the initial traffic stop was improper.
- The appellate court remanded for proper Krankel proceedings; new (Krankel) counsel was appointed, but after a hearing, the trial court again denied relief.
- On further appeal, the court affirmed the conviction and all relevant rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Reasonable suspicion for traffic stop | Officer had articulable suspicion (§401 violation) | No reasonable suspicion; dashcam showed Maury not following too closely | Stop was justified; denial of suppression affirmed |
| Limitation of defense evidence at suppression hearing | Evidentiary rulings violated right to challenge stop | Court wrongly excluded evidence and limited impeachment, impairing defense | No plain error; evidentiary rulings not structural |
| Denial of pro se representation post-trial | Court properly denied repeated, equivocal, dilatory pro se requests | Maury had an unequivocal right to proceed pro se post-trial | Denial was proper; request was dilatory |
| Sentencing factors (double enhancement) | Considered all proper factors; referenced impact but not for double count | Court improperly used harm/amount inherent in offense as aggravation factor | No error: facts exceeded statutory minimum; affirmed |
| Ineffective assistance by Krankel counsel | Counsel reasonably chose strongest claims and arguments | Krankel counsel required to present all nonfrivolous pro se ineffectiveness arguments | Downs not followed; counsel can exercise judgment |
Key Cases Cited
- People v. Krankel, 102 Ill. 2d 181 (Ill. 1984) (establishes procedure for handling pro se claims of ineffective assistance)
- People v. Hackett, 2012 IL 111781 (Ill. 2012) (clarifies standard for reasonable articulable suspicion for traffic stops)
- People v. Strickland, 466 U.S. 668 (U.S. 1984) (sets out the standard for ineffective assistance of counsel)
- People v. Fern, 189 Ill. 2d 48 (Ill. 1999) (addresses trial court’s discretion in sentencing)
- People v. Slater, 228 Ill. 2d 137 (Ill. 2008) (standard for reviewing suppression decisions)