Illinois Appellate Court
Criminal Court
Ineffective Assistance of Counsel
Evidence
Defendant was convicted of cyberstalking, harassment through electronic communication, and stalking. Evidence showed that Defendant left victim several voice mail phone messages threatening to kill her, thus State proved that Defendant transmitted threat of immediate or future bodily harm. Trial court addressed Defendant's pro se claims of ineffective assistance of counsel by inquiring of trial counsel, who explained circumstances of claims. Conviction and sentence for harassment through electronic communication vacated as violative of one-act, one-crime rule, but convictions and sentences for cyberstalking and stalking affirmed.