People v. Bell

Defendant was convicted, after bench trial, of unlawful delivery of a controlled substance within 1000 feet of a church and other related charges. Defendant filed pro se motion alleging ineffective assistance by trial counsel. At hearing, court did not inquire into Defendant's complaint about his counsel's performance. Remanded for court to conduct inquiry into Defendant's pro se posttrial claim of ineffective assistance of counsel, pursuant to People v. Krankel. Allegations in Defendant's pro se motion were sufficient to trigger court's duty to conduct such inquiry, as Defendant explicitly alleged he was denied effective assistance of counsel. (HOLDER WHITE and TURNER, concurring.)