People v. Watts

── People v. Watts ── Court: Appellate Court of Illinois Date: April 17, 2026 Category: General 2026 IL App (4th) 250533 FILED April 17, 2026 NO. 4-25-0533 Carla Bender 4th District Appellate IN THE APPELLATE COURT Court, IL OF ILLINOIS FOURTH DISTRICT THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) Morgan County CHARLES F. WATTS, ) Defendant-Appellant. ) No. 19CF226 ) ) Honorable ) Jeffery E. Tobin, ) Judge Presiding. JUSTICE HARRIS delivered the judgment of the court, with opinion. Presiding Justice Steigmann and Justice Lannerd concurred in the judgment and opinion. OPINION ¶1 Defendant, Charles F. Watts, argues that the trial court erred by dismissing his postconviction petition at the second stage of postconviction proceedings. Specifically, defendant contends that (1) he made a substantial showing of a claim of actual innocence, (2) he made a substantial showing of a claim that trial counsel was ineffective for failing to call an alibi witness, and (3) postconviction counsel failed to substantially comply with Illinois Supreme Court Rule 651(c) (eff. July 1, 2017) by failing to present defendant’s claims in proper legal form. The State argues that the amended postconviction petition was not dismissed at the second stage but was denied after a third-stage evidentiary hearing, and, accordingly, defendant’s second-stage arguments are meritless. The State also argues that the court properly denied the amended postconviction petition at the third stage, and postconviction counsel provided a reasonable level of assistance. We affirm. ¶2 I. BACKGROUND ¶3 A. Bench Trial and Direct Appeal ¶4 Following a bench trial in 2021, the trial court found defendant guilty of aggravated battery with a firearm (720 ILCS 5/12-3.05(e)(1) (West 2020)), and it sentenced him to 18 years of imprisonment. ¶5 We described the evidence presented at the bench trial in detail in our order in defendant’s direct appeal. See People v. Watts, 2022 IL App (4th) 210620-U, ¶¶ 6-27. However, we will briefly summarize the relevant evidence here. The trial evidence showed that James Trotter was shot at Melinda Heaser’s apartment on the night of the incident shortly before 6:45 p.m. Trotter testified that he had not been drinking alcohol or using drugs at Heaser’s apartment before he was shot, and he was not under the influence of alcohol or drugs to the point that his ability to observe and recall the incident was impaired. Trotter testified that defendant entered the apartment after knocking on the door. A few minutes later, defendant pulled out a gun and shot Trotter. Trotter stated he was able to clearly view defendant’s face prior to the shooting. Trotter stated he recognized defendant and had seen him on two or three prior occasions, though he only knew him by the nickname “