People v. Smith

Defendant was convicted, after bench trial, of being an armed habitual criminal, and 2 counts of unlawful use of possession of a weapon by a felon. State rested without presenting any additional evidence or requesting that court take judicial notice of anything that might establish that Defendant was the person named in a particular criminal case, and thus State failed to establish that Defendant was the person named in that case. Thus, Defendant's conviction for being an armed habitual criminal is vacated. Defendant's custodial statements and a certified statement of conviction in another criminal case was sufficient to establish that Defendant committed unlawful use or possession of a firearm by a felon beyond a reasonable doubt. Trial judge conducted a proper inquiry, which met the requirements of Krankel, on Defendant's posttrial claim of ineffective assistance of counsel. (REYES and MARTIN, concurring.)