People v. Bates

Defendant was convicted, after jury trial, of home invasion and 2 counts of aggravated criminal sexual assault. Court granted State's motion to use evidence of other sex offenses; State alleged that in both instances (within 1 month), Defendant, armed with a knife, broke into victim's dwelling and sexually assaulted her. Similarities between those 2 cases were stark and overwhelming, and DNA evidence against Defendant was substantial. Requirement of Krankel hearing applies only to posttrial claims raised by a defendant pro se.  

(DeARMOND and TURNER, concurring.)