People v. Keys

Defendant was found guilty of first-degree murder and that he personally discharged a firearm that was a proximate cause of the victim’s death. Defendant was also found guilty of several counts of concealment of a homicidal death and dismembering a human body. On appeal, defendant argued that he was denied the effective assistance of trial counsel because trial counsel failed to seek suppression of a video-recorded interview, did not seek to redact inadmissible statements made by police and suggestions of other crimes, and in requesting a limiting instruction concerning the inadmissible statements. Defendant also sought to vacate several of his convictions for dismemberment and concealment. The Illinois Supreme Court found that trial counsel did not provide ineffective assistance of counsel because defendant could not establish prejudice. The court further concluded that defendant was improperly convicted of multiple counts of dismemberment and concealment. (THEIS, NEVILLE, OVERSTREET, CUNNINGHAM, ROCHFORD, and O’BRIEN, concurring)