People v. Ratliff

Summary

The court vacated the appellate court's judgment because the appellate court lacked jurisdiction to review the defendant's guilty-plea judgment under the original notice of appeal and lacked authority to permit the untimely amended notice. Exercising supervisory authority, the court held that the defendant waived his Rule 401(a) claim by pleading guilty and by failing to raise it in a postplea motion, and that any Rule 401(a) violation was not second-prong plain error because it was not structural error. The court therefore affirmed the circuit court's judgment.