People v. Harris

Illinois Appellate Court
Criminal Court
Delivery of a Controlled Substance
Citation
Case Number: 
2020 IL App (3d) 160169
Decision Date: 
Friday, September 18, 2020
District: 
3d Dist.
Division/County: 
Whiteside Co.
Holding: 
Affirmed.
Justice: 
CARTER

Defendant was convicted, after jury trial, of unlawful delivery of a controlled substance within 1000 feet of a school and sentenced to 14 years. Court sufficiently inquired into Defendant's pro se posttrial claim of ineffective assistance of counsel. Although it was improper for court to consider the conduct of posttrial counsel in other cases, any error was harmless as court correctly found that basis of ineffective assistance claim lacked any merit. Court granted Defendant's request to proceed pro se at trial, but denied his request to appoint new standby counsel to assist him after current standby counsel was allowed to withdraw. Court admonished Defendant several times about self-representation and each time chose to proceed pro se, and court commented that Defendant was able to argue his points, including his entrapment defense, coherently; the evidence was not complicated. Any error in court refusing to allow jurors to take notes during trial was harmless, as evidence of Defendant's guilt was overwhelming. (HOLDRIDGE, concurring; McDADE, dissenting.)