Illinois Appellate Court
Criminal Court
Right to Counsel
Defendant was convicted, after jury trial, of criminal drug conspiracy. Court denied Defendant his constitutional right to self-representation on basis that Defendant was incapable of adequately representing himself, and thus committed structural error. Because Defendant made a clear and unequivocal choice to represent himself, after having been given proper admonitions, the court was required to honor his choice, unless court had found that Defendant had a mental disability that incapacitated him from understanding admonitions. (KNECHT and STEIGMANN, concurring.)