Illinois Appellate Court
Criminal Court
Right to Counsel
Defendant was convicted, after jury trial, of obstructing a peace officer. Nine months earlier, after case management conference, Defendant advised court that he wanted to represent himself, and court discharged appointed counsel, and Defendant then proceeded pro se. However, court failed to strictly comply with Rule 401(b)'s requirement that a Defendant's waiver of counsel must be recorded verbatim, as proceedings were not transcribed or otherwise recorded verbatim. Thus, Defendant's waiver of counsel was ineffective. (CATES and CHAPMAN, concurring.)