Illinois Appellate Court
Criminal Court
Post-Conviction Hearing Act
Defendant, who pled guilty to first-degree murder, appealed from a trial court order finding that defendant’s waiver of post-conviction counsel was knowing and intelligent. Defendant argued on appeal that the trial court incorrectly admonished him concerning the risks of self-representation. The appellate court affirmed, concluding that defendant’s waiver of counsel was knowing, voluntary, and intelligent and explaining that the trial court was not required to give defendant SCR 401 or 651(c) admonishments. (CAVANAGH and STEIGMANN, concurring)