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

The Fifth District held that the defendant forfeited his one-act, one-crime claim by entering a negotiated guilty plea and failing to move to withdraw it.

In People v. Rynders, 2024 IL App (5th) 220409-U, the defendant entered a negotiated plea of guilty to two counts of aggravated driving under the influence causing death. He was sentenced to 10 years in prison on each count, with the sentences to be served consecutively for a total of 20 years.

The defendant later sought postconviction relief, arguing that his two convictions violated Illinois’ one-act, one-crime doctrine. The Illinois Fifth District Appellate Court ultimately affirmed the denial of his amended postconviction petition. The court held that because the defendant entered a negotiated guilty plea, received concessions from the State, and never filed a motion to withdraw his guilty plea, he forfeited his ability to challenge the multiple convictions in the postconviction proceeding.

Quick Answer

The appellate court affirmed the denial of postconviction relief. Importantly, the court agreed with both sides that the two convictions violated the one-act, one-crime rule, but it concluded that the defendant had forfeited the claim because he did not timely move to withdraw his negotiated guilty plea. The decision therefore turned on the procedural effect of the guilty plea rather than whether the one-act, one-crime violation actually occurred.

The decision was filed on April 1, 2024, as a Supreme Court Rule 23 order. It is not precedential except in the limited circumstances allowed under Rule 23.

Background of the Case

On June 20, 2016, Jeffrey A. Rynders entered a negotiated plea of guilty to two counts of aggravated driving under the influence causing death.

According to the factual basis for the plea, two people died from injuries sustained when the motorcycle they were riding was struck by Rynders’ vehicle. The collision occurred after Rynders disobeyed a traffic control device that gave the motorcycle the right of way.

In exchange for the guilty plea, the State agreed to dismiss four additional felony charges arising from the collision and related conduct. The State also agreed to dismiss a number of misdemeanor and traffic charges and agreed to seek an aggregate sentence between 8 and 20 years.

Plea Agreement

Charges Dismissed

Four additional felony charges plus misdemeanor and traffic-related charges were dismissed.

Sentencing Range

The State agreed to seek an aggregate sentence of 8 to 20 years.

Actual Sentence

20 years total, consisting of two consecutive 10-year sentences.

During the plea hearing, the circuit court advised Rynders that the applicable sentencing range for aggravated DUI causing the deaths of two or more people was 6 to 28 years under 625 ILCS 5/11-501(d)(2)(G). The court also explained that the State had agreed to recommend no more than 20 years and no less than 8 years under the plea agreement.

Rynders confirmed that his attorney had correctly explained the terms of the agreement, that he understood the court’s admonishments, and that he was voluntarily entering the guilty plea.

On August 31, 2016, the circuit court sentenced Rynders to 10 years on each count, with the sentences to be served consecutively. His total sentence was therefore 20 years in the Illinois Department of Corrections.

Rynders Did Not Move to Withdraw His Guilty Plea

After sentencing, Rynders filed several pro se motions, including a motion for an extension of time to file postjudgment motions and a motion seeking a reduction of his sentence. Those motions were filed after the time permitted for ordinary postplea motions had expired.

Crucially, Rynders never filed a motion to withdraw his guilty plea. He also did not file a direct appeal from the judgment.

Approximately two and a half years after sentencing, Rynders filed a postconviction petition raising several claims of ineffective assistance of plea counsel. He alleged that counsel had failed to file a motion to withdraw his guilty plea or pursue an appeal even though Rynders had requested one.

Rynders also argued that allowing him to plead guilty to two counts of aggravated DUI causing death violated the one-act, one-crime doctrine.

The First Appeal

Rynders initially appealed the first-stage dismissal of his postconviction petition. In 2021, the Fifth District reversed that dismissal and remanded the matter for appointment of counsel and further proceedings. The appellate court concluded that Rynders had set forth the gist of a constitutional claim concerning the one-act, one-crime issue at that stage.

On remand, postconviction counsel filed an amended petition that abandoned the ineffective-assistance allegations and proceeded only on the one-act, one-crime argument. Rynders did not seek to withdraw his guilty plea.

The circuit court denied the amended petition, and Rynders appealed again. That second appeal resulted in the 2024 decision addressed in People v. Rynders, 2024 IL App (5th) 220409-U.

What Is the One-Act, One-Crime Doctrine?

Illinois’ one-act, one-crime doctrine generally prevents a defendant from being convicted of multiple offenses when the convictions are based on the same physical act, subject to the distinctions recognized by Illinois courts.

In People v. Rynders, 2024 IL App (5th) 220409-U, the State conceded that the defendant’s two aggravated DUI convictions were entered in violation of the one-act, one-crime rule. The Fifth District agreed with that point.

That concession did not, however, end the case. The appellate court had to determine whether Rynders could raise the issue years after voluntarily entering a negotiated guilty plea without first moving to withdraw that plea.

The Key Legal Question

The question was not simply whether the one-act, one-crime rule had been violated. The issue was whether Rynders could obtain postconviction relief after accepting a negotiated plea agreement, receiving substantial concessions from the State, and failing to timely move to withdraw his guilty plea.

The Appellate Court Focused on the Negotiated Guilty Plea

Illinois Supreme Court Rule 604(d) generally requires a defendant who wants to challenge a judgment entered after a guilty plea to first file the appropriate motion in the trial court, including a motion to withdraw the guilty plea and vacate the judgment when appropriate.

The Fifth District relied on Illinois Supreme Court precedent holding that a voluntary guilty plea generally waives nonjurisdictional errors or irregularities, including constitutional claims. The court also recognized that plea agreements are contracts and that waiver principles apply to negotiated plea agreements.

The court noted that this case involved more than an unconditional guilty plea. The State made significant concessions by dismissing multiple charges and agreeing to a sentencing range. Allowing Rynders to retain those benefits while later challenging the convictions without withdrawing the plea would effectively allow him to alter part of the negotiated agreement without returning the parties to their previous positions.

Why the Timing Mattered

Rynders did not challenge the plea agreement by filing a timely motion to withdraw his guilty plea. Instead, he waited until a later postconviction proceeding to raise the one-act, one-crime issue. The appellate court concluded that this procedural history barred the claim.

The Court Called the Claim Forfeited

The 2024 appellate order is particularly important because the court distinguished between the concepts of waiver and forfeiture. The court explained that these terms are sometimes used interchangeably in criminal cases, but Illinois law distinguishes them.

Waiver generally refers to the intentional relinquishment or abandonment of a known right. Forfeiture generally refers to the failure to timely assert a right. In People v. Rynders, 2024 IL App (5th) 220409-U, the court characterized the defendant’s failure to raise the issue in the required manner as forfeiture.

The appellate court also determined that Rynders was not challenging a void judgment. The circuit court had jurisdiction over both the defendant and the subject matter. As a result, the judgment was potentially voidable rather than void, meaning procedural rules could bar a later collateral challenge.

The Court Did Not Reverse the Convictions

The Fifth District ultimately affirmed the circuit court’s judgment denying Rynders’ amended postconviction petition. The court did not reverse the convictions or reduce the sentence based on the one-act, one-crime issue.

The result can seem unusual because the State itself conceded that the two convictions violated the one-act, one-crime rule. However, the appellate court explained that the procedural requirements surrounding negotiated guilty pleas prevented Rynders from obtaining relief through the postconviction proceeding after he failed to move to withdraw his plea.

Appellate Result

Total Years

Two consecutive 10-year sentences

Affirmed

Appellate Result

Postconviction denial upheld

What People v. Rynders Means for Illinois Criminal Cases

People v. Rynders, 2024 IL App (5th) 220409-U demonstrates why a defendant considering a guilty plea must understand the consequences of the agreement before entering the plea. A negotiated plea may result in substantial benefits, including dismissal of charges or an agreed sentencing recommendation, but the plea can also limit the defendant’s ability to challenge the resulting judgment later.

The case also shows why the procedures following a guilty plea are important. Under Illinois Supreme Court Rule 604(d), a defendant generally must take specific steps in the trial court before pursuing an appeal from a judgment entered after a guilty plea.

The decision does not establish that one-act, one-crime violations are automatically permissible whenever a defendant pleads guilty. Instead, the Fifth District held that this particular defendant could not obtain postconviction relief because he failed to preserve the challenge after entering a negotiated plea and receiving concessions from the State.

Talk to a Champaign, IL Criminal Defense Lawyer Today

The Champaign criminal defense lawyers at Patel Law, P.C. represent the interests of people charged with serious crimes in Illinois. If you are facing criminal charges or considering whether to challenge a conviction or guilty plea, call our office at 217-384-1111 to schedule a consultation and discuss your legal options.