People v. Yankaway, 2025 IL 130207

Jatterius L. Yankaway was arrested and charged with attempted first degree murder, aggravated battery, and unlawful possession of a weapon by a felon (UPWF) in Peoria County, Illinois, following the shooting of his cousin Robert Hunter.
At the time of his arrest and prosecution, COVID-19 emergency court orders had tolled statutory speedy-trial terms in Illinois, later restored in October 2021.
Yankaway, while incarcerated, was also convicted of a separate, unrelated weapons charge, affecting calculation of statutory speedy-trial deadlines.
Throughout pretrial proceedings, multiple continuances were granted for various reasons, including witness unavailability, COVID-19-related logistical complications, and crowded court dockets.
Despite pro se assertions and disputes over speedy-trial rights, defense counsel acquiesced to certain prosecution continuances, particularly a critical one from February to July 2022.
Yankaway was convicted after trial; the appellate court affirmed his convictions in part, vacated one conviction under the one-act, one-crime rule, and remanded for other sentencing issues. The Illinois Supreme Court granted review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance re: speedy-trial demand	Yankaway's counsel failed to file the proper speedy-trial demand under the intrastate detainers statute, prejudicing his defense	The State argued filing under the detainers statute was unnecessary; section 103-5(e) controlled and started automatically	Counsel was not ineffective for this failure; no demand was required under these facts
Defense counsel’s acquiescence to continuance	Counsel’s agreement to the February 2022 continuance was deficient performance, not attributable to Yankaway, and prejudiced his speedy-trial rights	Defense argued that the continuance was agreed to by both parties and any delay was attributable to the defense	Even if counsel’s performance was deficient, acquiescence was attributable to Yankaway and no Strickland prejudice shown
Sentencing range misapprehension	The circuit court misunderstood the minimum sentencing enhancement for attempted murder, impacting the sentence	The State contended the misstatement did not influence sentencing; factors focused on offense seriousness	Misstatement had no effect on sentencing; no plain error occurred
Appellate court remand for UPWF sentencing	Appellate court erred by remanding for sentencing on a vacated UPWF conviction	The parties agreed this was error	Supreme Court vacated the remand for UPWF sentencing

Strickland v. Washington, 466 U.S. 668 (sets the two-prong test for ineffective assistance of counsel)
People v. Cordell, 223 Ill. 2d 380 (discusses attribution of delay for speedy-trial purposes)
People v. Kliner, 185 Ill. 2d 81 (explains statutory calculation for multiple charges and speedy-trial periods)
People v. Staten, 159 Ill. 2d 419 (addresses applicability of the intrastate detainers statute)
People v. Turner, 128 Ill. 2d 540 (attributes agreed continuances to the defendant)
People v. Eddington, 77 Ill. 2d 41 (court’s sentencing misapprehension harmless when not influencing outcome)
People v. Mayfield, 2023 IL 128092 (affirmative agreements to continuances toll speedy-trial period)