People v. Allen 

Illinois Appellate Court
Criminal Court
Jury Selection
Fitness
Citation
Case Number: 
No. 1-08-0354
Decision Date: 
Tuesday, May 25, 2010
District: 
1st Dist.
Division/County: 
Cook Co., 2nd Div.
Holding: 
Affirmed.
Justice: 
KARNEZIS
Defendant was convicted of first-degree murder and home invasion, after proceeding pro se at trial. Court's analysis of his Batson challenge, claiming that State removed African-American men from jury but without specific supporting facts, properly ended at first stage, as Defendant did not make prima facie showing that State exercised its peremptory challenge on basis of race. No showing that Defendant was not mentally competent to proceed pro se at trial; his deficiencies in self-representation were not the result of mental incompetence, as record shows clear, verbal exchanges with court. Court was not required to apply higher standard for mental fitness to stand trial because Defendant was pro se. No error in State's comments in closing argument that Defendant seized control of his own defense by sitting alone at defense table, as State did not ask jury to draw negative inferences from his pro se representation.