Illinois Appellate Court
Criminal Court
Ineffective Assistance of Counsel
Appellate court's previous decision, on direct appeal, collaterally estops Defendant, who was convicted of first degree murder, from making claims of ineffective assistance of counsel in postconviction petition. Court had held that sentencing hearing was fair despite brief mention of an invalid aggravating factor, thus thus Defendant is collaterally estopped from claiming prejudice from trial counsel's failure to preserve error for review. (STEIGMANN and KNECHT, concurring.)