People v. Bates

This case presents question as to whether trial court should have conducted Krankel hearing, where defendant’s counsel asserted in request for new trial on defendant’s home invasion and aggravated sexual assault charges that he was ineffective by failing to adequately review certain victim and forensic evidence. Appellate Court found that no Krankel hearing was required, since Krankel hearing is required only in post-trial claims raised by pro se defendants. Appellate Court further noted that statements made by defendant’s counsel did not constitute clear admission of ineffective assistance of counsel, because counsel did not explicitly state that his performance was objectively unreasonable or prejudicial.