Illinois Appellate Court
Criminal Court
Right to Counsel
Court erred in denying Defendant's request to proceed pro se because court failed to find that Defendant suffers from a "severe mental illness" that would affect his competency to conduct his own defense. Defendant actively participated in defense counsel's arguments and motions, and filed a well-written and logical motion to proceed pro se. Courtroom outburst, after court denied his pro se request and his counsel's pretrial motions, was isolated incident and does not support denial of his constitutional right to forgo assistance of counsel. (CARTER and HOLDRIDGE, concurring.)