Illinois Appellate Court
Criminal Court
Jury Deliberations
A criminal defendant's right to a public trial is inapplicable to a portion of proceedings in which circuit court must answer jury's questions raised during deliberations. Court erred in allowing State, during hearing on defendant's pro se claims of ineffective assistance of counsel, to present arguments against defendant's claims and in support of defense counsel. Krankel inquiry had turned into an adversarial proceeding, undermining possibility of creating a neutral, objective record for review. (SCHMIDT, concurring; McDADE, specially concurring.)