Is Lawyer's Statement That He Examined Guilty Plea Hearing Transcript Mandatory ?

In People v. Mast, 305 Ill. App. 3d 727, 734-35, 713 N.E.2d 242, 238 Ill. Dec. 996 (1999), this court held that an attorney's certification was deficient because it failed to include a statement showing that the attorney had examined the transcript of the guilty plea hearing, as required by the rule. The certificate in that case stated that the attorney had " 'examined the trial court file and report of proceedings of the sentencing hearing.' " Mast, 305 Ill. App. 3d at 734. The State, asserting that strict compliance " 'does not necessarily mean literalistic compliance which ignores the reality of the situation at bar,' " argued that the certification satisfied the purpose of Rule 604(d), because the attorney examined the trial court file, which contained the transcripts of the guilty plea hearing, and because the attorney had represented the defendant at that hearing. Mast, 305 Ill. App. 3d at 733, 735. The court rejected this argument, deciding instead to follow the policy made emphatically clear by the supreme court: that strict compliance with each of the provisions set forth in Rule 604(d) is required. Mast, 305 Ill. App. 3d at 735.