People v. Anderson

The appellate court considered the impact of the supreme court’s recent decision in People v. Ratliff and whether a failure to comply with SCR 401(a) is cognizable as second-prong plain error. The appellate court, after considering the recent precedent, concluded that second prong plain-error review was unavailable and affirmed both the defendant’s convictions and sentence despite the trial court’s failure to provide the proper Rule 401(a) admonishments. (JORGENSEN and BIRKETT, concurring)