People v. Zirko

Illinois Appellate Court
Criminal Court
Substitution of Judge
Citation
Case Number: 
2021 IL App (1st) 162956
Decision Date: 
Friday, July 30, 2021
District: 
1st Dist.
Division/County: 
Cook Co., 5th Div.
Holding: 
Affirmed.
Justice: 
CUNNINGHAM

Defendant was convicted of 2 counts of 1st degree murder and 1 count of solicitation of murder. Without a showing of prejudice, it cannot be concluded that defense counsel was ineffective, or that counsel had a per se conflict of interest solely because he served as both trial counsel and postconviction counsel. Trial judgment's admonishment of counsel does not necessarily reflect animosity, hostility or ill will toward Defendant, and it did not "denigrate" defense counsel. Judge's comments were effort to maintain appropriate decorum in courtroom. (ROCHFORD, concurring; DELORT, specially concurring.)