People v. Harkey

Illinois Appellate Court
Criminal Court
Ineffective Assistance of Counsel
Citation
Case Number: 
2025 IL App (4th) 230523
Decision Date: 
Thursday, April 24, 2025
District: 
4th Dist.
Division/County: 
Winnebago Co.
Holding: 
Affirmed.
Justice: 
STEIGMANN

Defendant was convicted of four counts of aggravated criminal sexual assault, four counts of criminal sexual assault, one count of aggravated kidnapping, one count of home invasion, and one count of aggravated criminal sexual abuse and was sentenced to a total of 123 years in prison. After the trial, but prior to sentencing defendant filed a pro se post-trial motion claiming ineffective assistance of counsel. The trial court appointed the public defender who filed an amended post-trial motion, which the trial court denied. On appeal, defendant argued that the trial court erred when it appointed new counsel to represent defendant without conducting a Krankel inquiry. The appellate court disagreed and affirmed. (HARRIS and DeARMOND, concurring)