Illinois Supreme Court PLAs
Criminal Court
Conflict of Interest
This case presents question as to whether defendant’s trial counsel labored under per se conflict of interest in representing defendant in instant trial on charge of aggravated criminal sexual abuse where said counsel had acted four years earlier as guardian ad litem for victim of instant charged offense? Appellate Court held that counsel had per se conflict of interest and found that although said conflict was brought to trial court’s attention, new trial was still required since defendant was not advised or admonished about said conflict and did not waive it.