People v. McLaurin
2025 IL App (1st) 230791-U
Ill. App. Ct.2025Background
- Kenyatta McLaurin was convicted of being an armed habitual criminal, with his status predicated in part on a prior felony weapons conviction.
- He later petitioned for postconviction relief, arguing that one predicate conviction was void and his waiver of a jury trial was involuntary.
- The postconviction petition was summarily dismissed by the trial court as frivolous and patently without merit.
- On appeal, McLaurin pursued only two claims: (1) that his plea to the prior offense was to a void charge, and (2) that he waived his right to a jury trial only after being threatened by counsel.
- The appellate court examined the plea hearing transcript and record of the jury trial waiver colloquy.
Issues
| Issue | Plaintiff's Argument | Defendant's (State's) Argument | Held |
|---|---|---|---|
| Validity of Predicate Conviction | Conviction was for a void offense; thus invalid as predicate | Plea was to a valid offense (unlawful use of weapon by a felon) | Plea was to a valid charge, not a void offense |
| Voluntariness of Jury Trial Waiver | Waiver was coerced by threat of attorney withdrawal | Waiver was knowing, voluntary; record rebuts claim | Record demonstrates valid, voluntary waiver |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes two-prong test for ineffective assistance of counsel)
- People v. Ramey, 152 Ill. 2d 41 (1992) (decision to waive a jury trial belongs solely to defendant)
- People v. Hodges, 234 Ill. 2d 1 (2009) (first-stage postconviction petitions must have arguable basis in law or fact)
- People v. Knapp, 2020 IL 124992 (Ill. 2020) (record can rebut claims of involuntary waiver raised in postconviction petitions)