Illinois Appellate Court
Criminal Court
Conflict of Interest
Defendant was convicted of seven counts of sexual offenses against his stepdaughter. Defendant had previously been convicted of same conduct as to his stepdaughter's friend, who had previously resided with Defendant and her mother, and whom defense counsel had previously represented as GAL in juvenile proceeding. Defense counsel had per se conflict of interest because of his prior commitments to other child victim, who would benefit from unfavorable verdict for Defendant. (LYTTON, concurring; SCHMIDT, dissenting.)