This case presents question as to whether trial court properly allowed defendant to represent himself during post-conviction hearing, under circumstances where: (1) defendant had refused to cooperate with two different assistant defenders; (2) defendant had obtained several continuances to unsuccessfully obtain private counsel; and (3) trial counsel had failed to warn defendant that his continued misconduct could result in waiver of his statutory right to counsel. Appellate Court, in reversing denial of defendant’s post-conviction petition and remanding matter for appointment of new counsel, found that trial court should have given said warning at time defendant was still represented by assistant defender and prior to time trial court allowed assistant defender to withdraw from case. (Dissent filed.)
Illinois Supreme Court PLAs
Criminal Court
Right to Counsel