People v. Jocko

Trial court is not required to conduct an inquiry, prior to trial, into allegations of ineffective assistance of counsel that are raised by a defendant pro se. Until the proceedings have concluded, there is no way to determine if counsel's errors affected the outcome and thus no way of establishing prejudice under the Strickland v. Washington test. (KILBRIDE, FREEMAN, THOMAS, GARMAN, KARMEIER, and THEIS, concurring.)