In re Johnathan T.

Illinois Supreme Court
Criminal Court
Juvenile Court Act
Ineffective Assistance of Counsel
Citation
Case Number: 
2022 IL 127222
Decision Date: 
Friday, January 21, 2022
Holding: 
Affirmed in part. Reversed in part.
Justice: 
NEVILLE

Respondent was adjudicated a delinquent minor under the Juvenile Court Act after he was found guilty of 10 counts of aggravated criminal sexual assault. He appealed, arguing the circuit court erred when it failed to conduct an inquiry into his pro se claim of ineffective assistance of counsel. The appellate court affirmed, finding that while respondent was entitled to a Krankel hearing he did not make statements sufficient to trigger an inquiry. The Supreme Court affirmed in part and reversed in part, finding that juveniles in delinquency proceedings are entitled to a preliminary Krankel inquiry regardless of whether counsel is retained or appointed, and that respondent made statements sufficient to give court notice of his claim of ineffective assistance of counsel. (ANNE M. BURKE, GARMAN, MICHAEL J. BURKE, OVERSTREET, and CARTER, concurring.)