IN THE
                               SUPREME COURT

                                            OF
                          THE STATE OF ILLINOIS




                                   (Docket No. 129402)

                THE PEOPLE OF THE STATE OF ILLINOIS, Appellee,
                        v. EMANUEL WELLS, Appellant.


                               Opinion filed March 21, 2024.



        JUSTICE NEVILLE delivered the judgment of the court, with opinion.

        Chief Justice Theis and Justices Overstreet, Holder White, Cunningham,
     Rochford, and O’Brien concurred in the judgment and opinion.

OPINION

¶1       Defendant, Emanuel Wells, entered into a fully negotiated plea agreement with
     the State. The key terms of the agreement were that (1) Wells would plead guilty
     to one count of unlawful possession of cannabis with the intent to deliver, (2) the
     State would dismiss the remaining counts, (3) Wells would receive the minimum
     six-year sentence, (4) Wells would pay a $100,000 street value fine, and (5) Wells
     would receive credit for the 54 days he had spent in custody. After the trial court
     sentenced Wells pursuant to the agreement, Wells filed a motion to receive credit
     for time he spent on home detention prior to the plea. The trial court denied the
     motion. The appellate court affirmed, holding that “a fully negotiated guilty plea
     constitutes a waiver of presentence custody credit not provided for in the plea
     agreement.” 

. We allowed Wells’s petition for
     leave to appeal (Ill. S. Ct. R. 315 (eff. Oct. 1, 2021)), and we now affirm the
     appellate court’s judgment.


¶2                                        I. BACKGROUND

¶3        On October 11, 2020, Wells was arrested at the Bloomington airport, where he
     had in his possession approximately 25 pounds of a substance containing cannabis.
     Wells was indicted on one count of cannabis trafficking (720 ILCS 550/5.1 (West
     2020)) and two counts of unlawful possession of cannabis with the intent to deliver
     (id. §§ 5(g), 4(g)). Wells remained in custody for 54 days from October 11, 2020,
     until December 3, 2020, when he posted bond.

¶4        As a condition of release, the trial court placed Wells on 24-hour GPS
     monitoring with an ankle bracelet. Wells had a curfew and was only permitted to
     leave his house for work, church, and medical appointments. In January 2021, the
     trial court relaxed the bond conditions to allow Wells to be out of his home from 9
     a.m. to 3 p.m. In April 2021, after defendant got a job as a forklift driver, the trial
     court extended Wells’s curfew to 8 p.m. Finally, on June 29, 2021, the trial court
     removed the bond conditions of GPS monitoring and curfew.


¶5                                        A. Plea Proceedings

¶6       On November 5, 2021, the parties agreed to a fully negotiated guilty plea. Wells
     pled guilty to count II of the indictment, the Class X felony of unlawful possession
     of cannabis with the intent to deliver. Wells received the statutory minimum 1 six-


         1
           Unlawful possession with intent to deliver, as charged, is a Class X felony. 720 ILCS 550/5(g)
     (West 2020). The sentence for a Class X felony “shall be a determinate sentence *** of not less than
     6 years and not more than 30 years.” 730 ILCS 5/5-4.5-25(a) (West 2020).




                                                    -2-
     year sentence and a street value fine of $100,000. The State agreed to dismiss the
     other two counts. 2

¶7       The following colloquy occurred at the plea hearing:

             “THE COURT: It’s my understanding that you’ve reached an agreement
         today to where you would be pleading guilty to that charge. You would pay the
         fines and costs that are summarized in the financial sentencing order that I’m
         showing to you. There would be a $100,000 street value fine, sentenced to six
         years in the Department. You have credit for 54 days at this point in time. Your
         fines and costs would be taken care of within three years from your release from
         the Department. ***

             Does that accurately state your agreement today?

             MR. WELLS: Yes, sir.”

¶8       The parties also executed a written plea agreement that was signed by the
     assistant state’s attorney, Wells, and Wells’s attorney. One provision of the
     agreement provides: “The Agreement is as follows *** The court will impose as an
     agreed sentence in this case the following: *** six years imprisonment in IDOC
     *** [and] CREDIT 10/11/2020 TO 12/03/2020 (54 DAYS).” The factual basis
     established that Wells arrived at the Bloomington airport with a checked bag that
     contained approximately 25 pounds or 11,702 grams of a substance containing
     cannabis packaged for sale. The trial court accepted the parties’ agreement and
     sentenced Wells consistent with the plea agreement.

¶9       Wells did not file a postplea motion or a direct appeal. Instead, on March 31,
     2022, Wells filed a motion titled “Motion for Order Nunc Pro Tunc” requesting that
     the trial court amend his mittimus to reflect credit for time he spent on “GPS
     Monitoring.” Wells requested credit for the period from December 3, 2020, to June
     16, 2021. 3 The trial court denied the motion in a docket entry that states,


         2
           We note that a conviction on one of the dismissed counts, cannabis trafficking, would have
     subjected Wells to a mandatory minimum sentence of 12 years. See 720 ILCS 550/5.1(b) (West
     2020) (providing that a “person convicted of cannabis trafficking shall be sentenced to a term of
     imprisonment not less than twice the minimum term” for a Class X felony).
         3
           Wells indicated the period totaled 166 days. The period actually totals 196 days.




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       “Defendant was given the correct pretrial detention credit on this case.”


¶ 10                             B. Appellate Court Proceedings

¶ 11       On appeal, Wells argued that (1) he was entitled by statute to an additional
       presentence custody credit of 208 days and (2) he did not explicitly agree to waive
       the additional credit. 

. The court first discussed
       the principle that a “fully negotiated guilty plea constitutes a waiver of presentence
       custody credit not provided for in the plea agreement.” 

. Based on that
       principle, the court held that, because Wells “bargained for a disposition providing
       for a specified amount of presentence credit and other significant benefits, he
       waived the right to any additional credit.” 

. Thus, the court affirmed the trial
       court’s judgment. 

.

¶ 12       We granted Wells’s petition for leave to appeal. Ill. S. Ct. R. 315(a) (eff. Oct.
       1, 2021).


¶ 13                                      II. ANALYSIS

¶ 14       Wells again argues that he is entitled to statutory credit for the 208 days he spent
       on home detention. Wells contends that the appellate court improperly found
       waiver where the parties’ plea agreement was silent as to credit for the time he spent
       on home detention. The State primarily argues that Wells waived any additional
       sentencing credit by entering into the fully negotiated plea agreement.


¶ 15                    A. Wells Did Not Forfeit His Rule 472 Argument

¶ 16       The State initially argues that Wells forfeited his argument that he is entitled to
       the additional credit because he mischaracterized his request for credit as a “Motion
       For Order Nunc Pro Tunc” instead of a motion under Illinois Supreme Court Rule
       472 (eff. May 17, 2019). The State continues that Wells further did not invoke Rule
       472 until his reply brief in the appellate court. We disagree with the State’s
       forfeiture argument. Wells’s motion asked the trial court to correct his mittimus to
       reflect credit that he believed he was entitled to. Rule 472 provides that “the circuit
       court retains jurisdiction to correct *** [e]rrors in the calculation of presentence




                                                -4-
       custody credit.” Ill. S. Ct. R. 472(a)(3) (eff. May 17, 2019). The substance of
       Wells’s motion is consistent with the remedy available in Rule 472, and thus, we
       find that he did not forfeit his Rule 472 argument. See People v. Patrick, 

 (“Generally, the character of a motion is determined by its content
       or substance, not by the label placed on it by the movant.”).


¶ 17                            B. Custody for Home Detention

¶ 18      Wells claims he is entitled to credit for the time he spent on home detention
       under section 5-4.5-100(b) of the Unified Code of Corrections (730 ILCS 5/5-4.5-
       100(b) (West 2020)). Section 5/5-4.5-100(b) provides:

          “The trial court shall give credit to the defendant for time spent in home
          detention on the same sentencing terms as incarceration as provided in Section
          5-8A-3 (730 ILCS 5/5-8A-3). Home detention for purposes of credit includes
          restrictions on liberty such as curfews restricting movement for 12 hours or
          more per day and electronic monitoring that restricts travel or movement.
          Electronic monitoring is not required for home detention to be considered
          custodial for purposes of sentencing credit.” 

¶ 19       Wells contends he is entitled to credit for the entire 208 days he was on any
       form of home detention. The State agrees that, plea agreement aside, Wells would
       be entitled to credit for 127 days. The State questions whether Wells would be
       entitled to credit for the 81 days he spent on electronic monitoring under less
       restrictive conditions. The dispositive issue on Wells’s claim for credit is whether
       Wells, by entering into a fully negotiated guilty plea that granted him 54 days of
       credit, agreed to forgo his right to credit for the time he spent on home detention.


¶ 20                     C. Plea Agreements Under Contract Principles

¶ 21       This court has long held that plea agreements are governed to some extent by
       contract law principles. See People v. Evans, 

 (1996). “A plea
       agreement results when the prosecutor and the defendant exchange promises to
       perform or refrain from performing specified actions.” People v. Navarroli, 121 Ill.




                                              -5-
       2d 516, 521 (1988). The construction of a contract presents a legal issue we review
       de novo. Valerio v. Moore Landscapes, LLC, 

.

¶ 22       “An agreement, when reduced to writing, must be presumed to speak the
       intention of the parties who signed it.” Western Illinois Oil Co. v. Thompson, 

 (1962). “A contract is integrated when the parties intend it to be a final
       and complete expression of the agreement between them.” Midwest Builder
       Distributing, Inc. v. Lord & Essex, Inc., 

 (2007). When a
       contract is integrated, additional terms may not be added. See Armstrong Paint &
       Varnish Works v. Continental Can Co., 

 (1921) (“If [the contract]
       imports on its face to be a complete expression of the whole agreement,—that is,
       contains such language as imports a complete legal obligation,—it is to be
       presumed that the parties introduced into it every material item and term, and parol
       evidence[ 4] cannot be admitted to add another term to the agreement although the
       writing contains nothing on the particular term to which the parol evidence is
       directed.”).

¶ 23       Instead, in what we have described as the “ ‘four corners’ ” rule, a court initially
       “looks to the language of a contract alone.” Air Safety, Inc. v. Teachers Realty
       Corp., 

 (1999). “If the language of the contract is facially
       unambiguous, then the contract is interpreted by the trial court as a matter of law
       without the use of parol evidence.” 

 Consistent with the “four corners” rule, we
       have stated that neither party to a plea agreement should be able “ ‘unilaterally to
       renege or seek modification simply because of uninduced mistake or change of
       mind.’ ” Evans, 

 (quoting United States v. Harvey, 

 (4th Cir. 1986)); People v. Whitfield, 

 (2005) (“[W]hen a
       defendant enters a negotiated plea of guilty in exchange for specified benefits, such
       as the dismissal of certain counts or the promise of a certain sentence or sentencing
       recommendation, both the State and the defendant must be bound by the terms of
       the agreement.” (Emphasis in original.)).

¶ 24       Based on these principles, we hold that, where a fully negotiated plea deal
       represents a complete and final expression of the parties’ agreement, a presumption
       arises that every material right and obligation is included and neither party may

           4
           “Parol evidence” is evidence “extraneous” to the written contract. Black’s Law Dictionary
       1117 (6th ed. 1990).




                                                   -6-
       unilaterally seek modification of the agreement. 5 Applied to this case, a
       presumption arises that the parties intended for Wells to receive exactly 54 days of
       credit because that was a clear and unambiguous term of the agreement. The plea
       deal here is a complete and final expression of the agreement between Wells and
       the State. The fully negotiated plea agreement encompassed all relevant
       considerations, and the parties expected the trial court to immediately enter a final
       judgment consistent with the terms of the agreement. In fact, specific terms in the
       written agreement, signed by Wells himself, made the agreement contingent on the
       trial court imposing a 6-year sentence with credit for 54 days. There is no ambiguity
       in what the parties intended the sentence and credit to be. Thus, the parties are
       bound by the terms of the written agreement. Wells is not entitled to additional
       credit not included in the agreement.

¶ 25       We recognize Wells’s argument that a typical waiver did not occur here. As
       Wells argues, a waiver is the “intentional relinquishment of a known right.” Home
       Insurance Co. v. Cincinnati Insurance Co., 

 (2004). On this
       record, it is not clear if Wells was aware of the potential credit for his time spent on
       home detention. However, Wells waived the right to the statutory credit by entering
       into a fully negotiated plea agreement that provided for 54 days of credit. Wells is
       foreclosed from now modifying the credit term of the agreement by adding 208
       days of credit.

¶ 26        Wells speculates that the lack of credit was an oversight in the parties’
       agreement. In his view, the parties were mutually mistaken in not informing the
       trial court that he was entitled to the additional 208 days of credit. We have
       recognized that “contracting parties’ mutual mistake may be rectified by recourse
       to contract reformation [citation], where they are in actual agreement and their true
       intent may be discerned.” People v. Donelson, 

. However, the
       State has steadfastly rejected Wells’s claim to the credit not included in the parties’
       agreement, and there is no other indication in the record that the parties intended




            5
              This holding is qualified by our previous recognition that the application of contract principles
       to plea agreements is tempered in some instances by due process concerns. See Evans, 

. Wells has not raised any due process concerns specific to his case, and thus, we need not
       analyze when the enforcement of a plea agreement may raise constitutional concerns.




                                                        -7-
       Wells to receive more than the 54 days agreed upon. Thus, there is no mutual
       mistake.

¶ 27       To the extent that there was an “uninduced mistake” on Wells’s behalf, he
       cannot unilaterally seek to modify the credit term of the agreement. Evans, 

. Instead, Wells must allege that the plea of guilty was not made
       voluntarily and with full knowledge of the consequences. See Whitfield, 

. However, Wells has not attempted to invalidate the plea. Instead, he
       seeks to maintain the benefits of the plea agreement, the dismissal of charges and
       minimum sentence, while increasing the amount of credit he receives.

¶ 28       Finally, we overrule the appellate court decisions relied on by Wells to the
       extent that they are inconsistent with our decision. See People v. Ford, 

 (“[B]ecause the record does not conclusively show that the
       parties agreed to exclude such credit, we vacate the trial court’s denial of the Rule
       472 motion.”); People v. Malone, 

 (“[W]here the
       record does not conclusively show that the parties agreed to exclude credit as part
       of the plea agreement, the circuit court should not deny a defendant’s motion to
       amend the mittimus to reflect the credit.”). 6 Contrary to these cases, the
       presumption runs in favor of enforcing the specific terms of a plea deal that is a
       complete and final expression of the parties’ agreement.


¶ 29                                     III. CONCLUSION

¶ 30       We conclude that the parties entered into a complete and final plea agreement
       that unambiguously provided Wells credit of 54 days for time served. Because the
       plea agreement is unambiguous, the parties are bound by the terms of the
       agreement. We decline Wells’s invitation to unilaterally modify the agreement by
       adding 208 days of credit. We therefore affirm each of the lower courts’ decisions.


¶ 31       Judgments affirmed.



           6
            We note that we overrule these cases on the specific basis described. We need not reach
       whether the result of either case would be different under the holding we reach.




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