People v. Crenshaw

── People v. Crenshaw ── Court: Appellate Court of Illinois Date: May 14, 2026 Category: General 2026 IL App (4th) 250803 FILED May 14, 2026 NO. 4-25-0803 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. ) Winnebago County MICHAEL P. CRENSHAW, ) No. 00CF727 Defendant-Appellant. ) ) Honorable ) Scott Paccagnini, ) Judge Presiding. PRESIDING JUSTICE STEIGMANN delivered the judgment of the court, with opinion. Justices Knecht and Grischow concurred in the judgment and opinion. OPINION ¶1 In March 2001, defendant, Michael P. Crenshaw, entered an open guilty plea to the charge of first degree murder (720 ILCS 5/9-1(a)(1) (West 2000)), and the trial court sentenced him to 50 years in prison. ¶2 Defendant appealed, arguing that his sentence was unreasonably disparate to that of his codefendant, who received a 30-year sentence. The Second District disagreed and affirmed defendant’s sentence. People v. Crenshaw, 341 Ill. App. 3d 1118 (2003) (table) (unpublished order under Illinois Supreme Court Rule 23). ¶3 Over the last 20 years, defendant has repeatedly filed postconviction petitions and other various collateral attacks regarding his conviction and sentence. The trial courts and the appellate court have rejected each of defendant’s attacks. ¶4 The present case is merely the latest in his long line of groundless attacks. In June 2025, defendant filed 10 distinct motions for leave to file a successive postconviction petition. These 10 distinct motions constituted defendant’s 24th through his 33rd collateral filings. ¶5 In July 2025, the trial court entered an order denying defendant’s request for leave to file his 10 successive postconviction petitions, noting that the court found defendant’s claims were “frivolous as he has either raised or could have raised each of his claims in prior proceedings. Therefore, [defendant] has failed to make the requisite showing of either cause and prejudice, or actual innocence, that is necessary to allow for successive postconviction proceedings.” ¶6 Defendant appealed, and the Office of the State Appellate Defender (OSAD) was appointed to represent him. In January 2026, OSAD filed a motion to withdraw as counsel on appeal because “an appeal in this case would be without arguable merit.” OSAD also filed a memorandum of law in support of that motion, which set forth (1) a full statement of facts, (2) a list of potential issues on appeal, and (3) the reasons why each of those potential issues does not merit review. ¶7 OSAD mailed a copy of the motion to defendant, and he has filed a written objection. ¶8 For the reasons that follow, we grant OSAD’s motion to withdraw, affirm defendant’s conviction and sentence, and impose a sanction of $20,000 upon defendant, pursuant to Illinois Supreme Court Rule 375(b) (eff. Feb. 1, 1994), for his filing this frivolous appeal. ¶9 I. BACKGROUND ¶ 10 A. The Trial Court Proceedings ¶ 11