People v. Mineau, 19 N.E.3d 633

Mineau was indicted in 2009 for burglary and unlawful possession of a stolen motor vehicle; he pled guilty to the unlawful-possession charge and the burglary charge was dismissed.
Hannigan, then representing Mineau, moved to withdraw the plea or reconsider sentence; Doll was later assigned as public defender and questioned Mineau at the hearing.
A Rule 604(d) certificate was filed by Hannigan; Doll appeared at the hearing and argued on Mineau's behalf; the trial court denied the motion and Mineau appealed.
The initial appellate disposition affirmed, but the supreme court directed reconsideration in light of Tousignant, leading to a renewed analysis.
Rule 604(d) requires a certificate stating consultation with the defendant about errors in both the sentence and the plea; it must reflect consultation and the attorney’s review of the court file and proceedings.
The court held that Hannigan’s certificate was sufficient, Doll did not need a separate certificate, and the use of 'or' in the certificate complied with Tousignant when read in context.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Doll needed his own Rule 604(d) certificate	Mineau	Mineau	No; certificate by Hannigan suffices
Whether Hannigan's Rule 604(d) certificate complies after Tousignant	Mineau	Mineau	Certificate satisfies the rule; 'or' means 'and' per Tousignant, thus compliant

People v. Love, 385 Ill. App. 3d 736 (2008) (strict compliance with Rule 604(d) certificate required; remand when violated)
People v. Herrera, 2012 IL App (2d) 110009 (2012) (distinct counsel at hearing requires compliant certificate from the present attorney)
People v. Ritchie, 258 Ill. App. 3d 164 (1994) (certificate not by the attorney actually representing the defendant at the hearing)
People v. Wyatt, 305 Ill. App. 3d 291 (1999) (certificate need not recite verbatim the rule's language)
Tousignant, 2014 IL 115329 (2014) (or in Rule 604(d) means 'and' for consultation on both plea and sentence)