Illinois Supreme Court PLAs
Criminal Court
Ineffective Assistance of Counsel
This case presents question as to whether trial court, when conducting Krankel hearing to determine whether defendant was entitled to new post-trial counsel based on claim that his trial counsel was ineffective, erred by allowing govt. to question defendant’s trial counsel under oath while barring defendant from asking any questions. Appellate Court found that although trial court had erred in allowing govt. to question defense counsel under oath, any error was harmless where: (1) trial court thoroughly examined factual matters of case and questioned both defendant and his trial counsel in impartial manner; and (2) both claims of ineffective assistance of counsel that were fully developed were without merit.