Illinois Appellate Court
Criminal Court
Right to Counsel
Defendant pled guilty to DUI and was sentenced to one year of supervision. Fourteen months later, court revoked Defendant's supervision and resentenced him to 18 months probation and 60 days in county jail. Court appointed two attorneys, but allowed both to withdraw given their difficulties in obtaining Defendant's cooperation. Defendant never expressly rejected court's offer to appoint counsel for him, but court denied Defendant's request for continuance to obtain new attorney, after telling trial court that he did not have enough money to retain his own attorney. Court erred in forcing Defendant to proceed pro se at revocation hearing. (APPLETON and COOK, concurring.)