Illinois Supreme Court Rule 604(D) - Interpretation
In People v. Starks, 344 Ill. App. 3d 766, 800 N.E.2d 1239, 279 Ill. Dec. 656 (2003), the Fourth District found that a review of the complete record demonstrated that the attorney complied with the requirements of Rule 604(d), even though the attorney failed to certify that he had examined the trial court file and the report of proceedings of the guilty plea.
The record showed that the attorney received the transcripts, which were used by the State to cross-examine the defendant and were admitted into evidence at a hearing, during which the attorney asked questions that showed a knowledge of the transcripts. Starks, 344 Ill. App. 3d at 769-70.
Based on the record, the court found strict compliance with Rule 604(d), reasoning that if the record demonstrates that the purpose of Rule 604(d) is satisfied, remand for a word change is a waste of judicial resources. Starks, 344 Ill. App. 3d at 769.