People v. Frey

Summary

The Illinois Supreme Court held that postconviction counsel's Rule 651(c) certificate created a rebuttable presumption of reasonable assistance that the petitioner failed to overcome. Because the petition was ambiguous about whether it asserted a standalone due process claim concerning a jury note, counsel's failure to discuss that claim in the withdrawal motion did not establish noncompliance with Rule 651(c). The court reversed the appellate court and affirmed the circuit court's orders permitting counsel to withdraw and dismissing the petition.