People v. Saleh, 995 N.E.2d 375

Saleh pled guilty to misdemeanor DUI on April 24, 2009 and received one year of supervision with fines.
State petitioned to revoke supervision based on multiple violations, including a threatening letter; a supplemental petition followed.
On January 10, 2011 Saleh stipulated to the supervision violation and was sentenced to 364 days in the Cook County jail; judgment on the underlying DUI was entered separately.
The trial court did not admonish Saleh under Rule 402A or determine voluntariness or a factual basis for the stipulation.
Saleh appealed pro se; the appellate court vacated the judgment and remanded to allow withdrawal of the stipulation, due to lack of substantial compliance with Rule 402A.
The State argued mootness; the court held that although sentence completion may render the sentence moot, validity of the conviction may still be at issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 402A admonitions were required for the stipulation to revoke supervision	Saleh statutes unenforceable due to lack of admonitions.	People contends no admonitions were required in this context.	Yes; lack of Rule 402A admonitions invalidates the stipulation.
Whether the court properly determined voluntariness and factual basis for the stipulation	Saleh voluntarily stipulated; no coercion or lack of basis.	Court failed to confirm voluntariness or factual basis for the stipulation.	No; voluntariness and factual basis were not established.
Whether Saleh's challenge to the conviction should be considered despite completion of sentence	Challenge moot since sentence completed.	Conviction validity can still be reviewed; not moot.	Not moot for conviction validity; review allowed.
What remedy is appropriate for Rule 402A violation	Remand for proper admonitions and possible withdrawal of stipulation.	No remedy discussed beyond standard procedures.	Vacate judgment and remand to allow withdrawal of stipulation and further proceedings.

People v. Ellis, 375 Ill. App. 3d 1041 (2007) (substantial compliance standard for Rule 402A)
People v. Campbell, 224 Ill. 2d 80 (2006) (rejects mootness approach to conviction validity when challenge implicated)
People v. Dennis, 354 Ill. App. 3d 491 (2004) (admonition adequacy and separate issues under Rule 402A)
People v. Rozborski, 323 Ill. App. 3d 215 (2001) (supervision not final judgment; effect on underlying charges)
People v. Larimer, 409 Ill. App. 3d 827 (2011) (review of supervision-related proceedings; final disposition varies by context)
In re Christopher K., 217 Ill. 2d 348 (2005) (conviction consequences of nullification; comprehensive due process concerns)