In re J.W., 204 Ill.2d 50, 69, 272 Ill.Dec. 561, 787 N.E.2d 747 (2003). ¶ 45 Both parties agree that this court has previously addressed the issue of whether a minor in a delinquency proceeding has a right to relief under the Act and has found that he does not. See In re R.R., 75 Ill.App.3d 494, 495, 31 Ill.Dec. 159, 394 N.E.2d 75 (1979); In re A.W.H., 95 Ill.App.3d 1106, 51 Ill.Dec. 483, 420 N.E.2d 1041 (1981); see also In re Buchanan, 62 Ill.App.3d 463, 465, 19 Ill.Dec. 607, 379 N.E.2d 122 (1978) (collateral attack via Post–Conviction Hearing Act unavailable to juvenile offenders); In re Thomas, 77 Ill.App.3d 299, 300, 32 Ill.Dec. 918, 396 N.E.2d 31 (1979) (citing In re Buchanan, 62 Ill.App.3d 463, 19 Ill.Dec. 607, 379 N.E.2d 122). In In re R.R. as well as In re A.W.H., this court specifically held that minor-respondents do not fall within the parameters of the Act, which clearly defines who can seek relief under the Act, because proceedings in juvenile court are not criminal trials that result in convictions.
On August 29, 1979, the minor filed a pro se post-conviction petition in which he alleged that at the July 1977 hearing he was (1) adjudicated delinquent based on insufficient evidence and (2) denied effective assistance of counsel. The trial court entered the following order on November 26, 1979: "Post-conviction Petition dismissed pursuant to In the Interest of R.R., 394 N.E.2d 75, 31 Ill. Dec. 159 (2d 1979). Notices.
Elson, although concerned and vigorous in his representation, also failed Clay. Second, as Clay points out, Illinois law limited the routes for relief available to her. For example, collateral remedies provided in the Illinois Post-Conviction Hearing Act, Ill.Rev.Stat. ch. 38, ¶ 122-1 et seq., have been held unavailable to juveniles in most circumstances. See In re A.W.H., 95 Ill. App.3d 1106, 1107, 51 Ill.Dec. 483, 484, 420 N.E.2d 1041, 1042 (5th Dist. 1981); In re R.R., 75 Ill.App.3d 494, 495-96, 31 Ill.Dec. 159, 160-61, 394 N.E.2d 75, 76-77 (2d Dist. 1979), cert. denied, 447 U.S. 928, 100 S.Ct. 3025, 65 L.Ed.2d 1122 (1980). Because there was little record of Clay's constitutional claims in the trial court, the most Clay could have hoped for on appeal was a remand to the trial court.
See, e.g., In re A.W.H., 95 Ill. App. 3d 1106, 1107 (1981); In re R.R., 75 Ill. App. 3d 494, 496 (1979). Accordingly, we hold that compliance with the Rule 604(d) certificate requirements is required in juvenile proceedings.
Additionally, application of the rule to juvenile proceedings is particularly important given that this court has not reviewed holdings of the appellate court concluding that relief from such proceedings is unavailable under the Post-Conviction Hearing Act. See, e.g., In re A.W.H., 95 Ill. App.3d 1106, 1107 (1981); In re R.R., 75 Ill. App.3d 494, 496 (1979). Accordingly, we hold that compliance with the Rule 604 (d) certificate requirement is required in juvenile proceedings.
Nonetheless, the application of such safeguards and standards does not transform delinquency proceedings into criminal proceedings or indicate that a fully adversarial process is developed. (See In re Beasley, 66 Ill. 2d at 390 (rejecting use of Supreme Court Rule 402 in delinquency process); People ex rel. Carey v. White (1976), 65 Ill.2d 193 (best interests of minors under traditional dispositional alternatives would not be served by jury trials); People ex rel. Hanrahan v. Felt (1971), 48 Ill.2d 171 (allowing civil discovery in juvenile practice, but permitting court, in its discretion, to regulate use); In re R.R. (1979), 75 Ill. App.3d 494 (petition for post-conviction relief not available in juvenile delinquency proceedings).) The Act contains no statement incorporating general criminal practice rules or the provisions of the Code of Criminal Procedure.
" Nor is a proceeding under the Juvenile Court Act denominated a "conviction." ( In re R.R. (1979), 75 Ill. App.3d 494.) Rather, such proceedings are to be administered in a spirit of humane concern for the minor and to promote both the welfare of the minor and the best interests of the community. Ill. Rev. Stat. 1979, ch. 37, par. 701-2; In re Beasley (1977), 66 Ill.2d 385, 389.
This court has consistently held that the act does not reach juvenile adjudications. See In re Vincent K, 2013 IL App (1st) 112915, ¶ 50; In Interest of R.R., 75 Ill.App.3d 494, 496 (1979); In Interest of A.W.H., 95 Ill.App.3d 1106, 1108 (1981).
Nor is a proceeding under the Juvenile Court Act denominated a ‘conviction.’ ( In re R.R. (1979), 75 Ill. App. 3d 494, 31 Ill.Dec. 159, 394 N.E.2d 75.) Rather, such proceedings are to be administered in a spirit of humane concern for the minor and to promote both the welfare of the minor and the best interests of the community. Ill. Rev. Stat. 1979, ch. 37, par. 701-2; In re Beasley (1977), 66 Ill. 2d 385, 389, 6 Ill.Dec. 202, 362 N.E.2d 1024.
Additionally, even if a state chose to provide postconviction collateral review of criminal convictions, there is no constitutional requirement for that state to extend such review to juvenile-delinquency proceedings. See, e.g., In Interest of R.R., 75 Ill.App.3d 494, 496, 31 Ill.Dec. 159, 394 N.E.2d 75, 76 (1979) (“We do not believe that the provisions of the Post–Conviction Act, directly applicable to criminal proceedings, should be extended to juvenile proceedings.”).