Illinois Appellate Court
Criminal Court
Waiver of Counsel
Defendant was convicted of first degree murder and was sentenced to 40 years in prison. On direct appeal, defendant argued that the trial court erred by finding that his fitness had been restored and in allowing him to proceed pro se despite his mental health issues and non-compliance with medication. The appellate court affirmed, finding that the trial court judgment finding defendant to be fit was not against the manifest weight of the evidence even though there was conflicting testimony and the trial court did not abuse its discretion when it concluded that defendant was competent to waive his right to counsel. (STEIGMANN and ZENOFF, concurring)