People v. Butler

Defendant was convicted, after bench trial, of 2 counts of aggravated criminal sexual assault and 1 count of kidnapping. Probable cause existed for police to arrest Defendant. The fact that some time passed before Defendant was apprehended is irrelevant to probable cause inquiry, given the nature of the offense. Victim’s “fairly general” physical description of her assailant did not preclude finding of probable cause. Court failed to conduct preliminary Krankel inquiry, given that when court asked Defendant if he was satisfied with his attorney Defendant replied, “I’m mixed on that,” yet court proceeded to sentencing without making any inquiry on the claim. (MIKVA and ODEN JOHNSON, concurring.)