People v. Strickland

Court deferred ruling on Defendant's motion in limine to bar his three prior convictions, brought per People v. Montgomery, per its "blanket policy" to defer ruling until after a defendant testifies. Record does not support finding of prejudice, because deferral could have made no difference in Defendant's decision not to testify; and Defendant forfeited his claim by failing to testify. Court admonished venire en masse of Zehr principles, and some raised their hands to address judge, but none stated any difficulty in understanding or accepting any of the four Zehr principles; this complied with Rule 431(b). No ineffective assistance of counsel, as counsel's manner of cross-examination of State's forensic scientist was matter of trial strategy; and no prejudice as evidence was overwhelmingly against Defendant.