People v. Medina

Defendant was convicted of driving while under the influence of alcohol, driving while license revoked, and driving without insurance. Defendant appealed on the basis that he was denied the effective assistance of counsel where counsel elicited allegedly harmful testimony at trial and that the trial court violated his constitutional rights where it denied defendant’s request for appointed counsel. The State conceded on appeal that trial counsel’s performance was deficient, but argued defendant was not prejudiced. The appellate court agreed, finding defendant did not establish how he was prejudiced by the deficient performance. The appellate court further found defendant forfeited his argument that the trial court erred by not appointing counsel and that he failed to establish plain error. The dissent disagreed, arguing that the trial court failed to consider the statutory requirements for representation by the public defender and that this constituted reversible error. (HAUPTMAN, concurring. LYTTON, dissenting.)