People v. Brown

Illinois Appellate Court
Criminal Court
Citation
Case Number: 
2013 IL App (2d) 110327
Decision Date: 
April 12, 2013
District: 
2d Dist.
Division/County: 
Winnebago Co.
Justice: 
HUDSON
Holding: 
Affirmed.
Whether to admonish a defendant as to his or her right to a bench trial is a matter within the trial court's discretion, and is a right that a defendant must assert. An on-the-record waiver of the right to bench trial is not required. Defendant was not denied his right to confrontation by court's admission of hearsay statement that child told his mother that Defendant pushed him. Child's statement occurred in a fast-paced confrontation and it concerned a threat to child's well-being, and thus was not testimonial. (JORGENSEN and BIRKETT, concurring.)