People v. Patrick

Defendant was convicted of reckless homicide after fatal collision at intersection. Trial court should not have dismissed Defendant's pro se requests as untimely, and was required to conduct preliminary inquiry into factual basis of Defendant's allegations of ineffective assistance of counsel. A pro se posttrial motion alleging ineffective asisstance of counsel is not a motion for new trial as outlined in Section 116-1 of Code of Criminal Procedure, but is part of a separate common law procedure for posttrial motions alleging ineffective assistance of counsel. (FREEMAN, THOMAS, GARMAN, KARMEIER, BURKE, and THEIS, concurring.)