Illinois Appellate Court
Criminal Court
Waiver of Counsel
Defendant, who elected to proceed pro so, was convicted of multiple counts of aggravated domestic battery and domestic battery as well as violation of domestic violence bond bail and criminal damage to property and was sentenced to a total of five years in prison. On appeal, defendant argued that his waiver of counsel was invalid because the SCR 401(a) admonishments were given nearly a month before he waived counsel and not at the time of the waiver. The appellate court agreed, reversed his conviction, and remanded for a new trial. (JORGENSEN and BIRKETT, concurring)