Defendant Appeals Convictions of DUI Causing Death on Ground of One-Act, One-Crime

In the case of People v. Rynders, the defendant was charged with two counts of DUI causing death. He entered a negotiated plea of guilty and was sentenced to 10 years for each charge to be served consecutively. He appealed his sentence. In this case, the appeals court found that the defendant waived his right to appeal when he entered the negotiated plea. Below, we’ll take a look at the case and how the court made its decision.

Background of the case 

In June 2016, the defendant entered a negotiated plea of guilty to two counts of aggravated DUI causing death. The defendant stipulated to the fact that two people died as a result of a traffic accident caused by the defendant. The victims were riding a motorcycle when the defendant struck them with his car after the defendant disobeyed a traffic control device that gave the motorcycle the right of way.

In exchange for the defendant’s guilty plea, the state agreed to dismiss four additional felony charges against the defendant related to his actions during the accident. The state also dismissed several misdemeanor and traffic-related charges and agreed to seek a sentence between 8 and 20 years.

The defendant acknowledged that his counsel had correctly cited the terms of the agreement and that he was voluntarily entering his plea. The circuit court informed the defendant that the applicable sentencing range for aggravated DUI causing death to two or more people was 6 to 28 years. However, pursuant to the plea agreement, the state would cap its recommendation to 20 years with a minimum of 8 years. The defendant acknowledged the court’s admonition and accepted the plea. The defendant was thus found guilty of two counts of aggravated DUI causing death and sentenced to 10 years on each charge for a total of 20 years.

The appeal 

Two years after the sentence was handed down, the defendant filed a pro se postconviction petition raising several claims of ineffective assistance of plea counsel. This included an allegation that defense counsel was ineffective for failing to file a motion to withdraw his guilty plea or file an appeal even after the defendant had requested one. He also argued that the trial court erred when it allowed him to plead guilty to both charges because the plea violated the “one-act, one-crime doctrine.”

In this case, the state argued that the defendant waived his right to file an appeal based on the one-act one-crime doctrine. Appeals can only address issues of constitutional magnitude and the one-act one crime doctrine does not apply. Further, because the defendant entered a negotiated plea that dropped other charges, prosecutors were able to pursue two counts against the defendant. The defendant’s appeal was ultimately denied.

Talk to a Champaign, IL Criminal Defense Lawyer Today 

The Champaign criminal defense lawyers at Patel Law, P.C. represent the interests of those charged with serious crimes in Illinois. Call our office today to schedule an appointment, and we can begin discussing your defense right away.

Source:

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