Defendant and her 3 co-defendants were tried jointly but in severed bench trials, and all were found guilty of armed robbery and stabbing death of victim. Defendant alleged, for the first time after trial, that she was denied her 6th amendment right to conflict-free counsel where attorneys from same law firm represented Defendant and 1 codefendant. Defendant's counsel decided to forgo asserting an innocence defense in favor of pursuing a joint defense of self-defense.Defendant failed to show that innocence defense based on a lack of accountability was a plausible alternative defense. Record shows that Defendant was guilty of murder under a common-design rule. Defendant failed to show actual conflict of interest. (KARMEIER, FREEMAN, THOMAS, KILBRIDE, GARMAN, and THEIS, concurring.)
Illinois Supreme Court
Criminal Court
Conflict of Interest