People v. Taylor, 99 N.E.3d 55

Defendant Thomas Taylor was indicted for unlawful use of a weapon (two counts) and aggravated unlawful use of a weapon for possessing and selling a short‑barreled shotgun; one count was later nol‑prossed.
Defendant waived a jury and proceeded to a stipulated bench trial: the parties submitted a seven‑page stipulation plus exhibits (shotgun, shell, audio/video) instead of live witness testimony.
During the plea/trial colloquy defense counsel and the court stated the stipulation was to the facts and that the court would decide guilt; defendant acknowledged the stipulation and agreed no witnesses would testify or be cross‑examined.
The court reviewed the exhibits, found the State proved guilt beyond a reasonable doubt on both counts, and sentenced defendant to 30 months’ probation (including 180 days in jail).
Defendant appealed, arguing a stipulated bench trial that is tantamount to a guilty plea requires Rule 402(a) admonishments and he did not receive them.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a stipulated bench trial here was tantamount to a guilty plea because defendant conceded the evidence was sufficient	Stipulating to the truth of facts is necessarily conceding sufficiency; no Rule 402(a) admonishments were needed because no guilty plea occurred	Taylor argued his stipulation admitted the facts but left sufficiency to the court, so he did not concede sufficiency and thus was not entitled to Rule 402(a) admonishments	Court held defendant did not concede sufficiency: he stipulated to facts only and left sufficiency to the court, so no Rule 402(a) admonishments were required
Whether defendant failed to preserve a defense such that the stipulation functioned as a guilty plea	State argued that preservation of a defense is what matters; if defendant did not preserve a defense the stipulation is tantamount to a guilty plea	Taylor argued he preserved a jurisdictional/constitutional defense (statute unconstitutional), which would survive a guilty plea and thus the stipulation was for preservation purposes, not a plea	Court held Taylor did preserve a defense (he asserted the statute was unconstitutional), so the stipulation did not function as a guilty plea and admonishments were not required

People v. Clendenin, 238 Ill.2d 302 (defines when a stipulation is tantamount to a guilty plea)
People v. Foote, 389 Ill. App.3d 888 (Rule 402 admonishments required if stipulation is tantamount to guilty plea)
People v. Davis, 286 Ill. App.3d 686 (discusses concession of sufficiency and preservation of defenses)
People v. Mitchell, 353 Ill. App.3d 838 (standard of review for whether stipulation equals guilty plea)
Blackledge v. Perry, 417 U.S. 21 (constitutional claims affecting state power are not waived by guilty plea)
People v. Nicholls, 71 Ill.2d 166 (authority cited regarding assessment of appellate costs)