Illinois Appellate Court
Criminal Court
Right to Self-Representation
(Modified upon denial of rehearing 1/19/18.) Defendant was convicted, after bench trial, of 1st-degree murder and sentenced to 33 years. Court clearly abused its discretion when it denied Defendant's unequivocal and unambiguous request to represent himself, based on its belief that request was not in Defendant's best interest, rather than deytermining whether Defendant's request was voluntarily, knowingly, and intelligently made. Error is second-prong plain error. Remanded for new trial. (HUDSON and BURKE, concurring.)