Illinois Appellate Court
Criminal Court
Effective Assistance of Counsel
Defendant was found guilty of first-degree murder and appealed, arguing that the trial court abused its discretion when it denied defendant's motion for a new trial because his trial counsel failed to complete his MCLE requirements. The appellate court affirmed, observing that a failure to comply with MCLE does not mean that an attorney is incapable of providing adequate representation and that admission to the bar is the proper indicator of an attorney’s fitness to practice law, not completion of continuing education requirements. (LYLE and NAVARRO, concurring)