Illinois Appellate Court
Criminal Court
Waiver of Counsel
Defendant was found guilty of first-degree murder and sentenced to 30 years in prison. The sole issue on appeal was whether defendant’s waiver of trial counsel and election to proceed pro se substantially complied with SCR 401(a). The appellate court held that it did not because the record could not establish that defendant’s decision was made with full awareness of both his rights and the consequences of his decision to abandon those rights. (HOFFMAN and ROCHFORD, concurring)