People v. Anderson

Illinois Appellate Court
Criminal Court
Waiver of Counsel
Citation
Case Number: 
2024 IL App (2d) 230077
Decision Date: 
Monday, February 5, 2024
District: 
2d Dist.
Division/County: 
Kane Co.
Holding: 
Reversed in part, vacated in part, remanded.
Justice: 
McLAREN

Defendant was convicted of nine counts, including two counts of aggravated domestic battery and two counts of violation of a domestic violence bail bond, and was sentenced to a term of five years in prison. Defendant appealed, arguing that his waiver of right to counsel was invalid because the SCR 401(a) admonishments were required to be given to him when he told the court he wanted to waive counsel and in this case the admonishments were given 26 days prior to the waiver. The trial court agreed and reversed defendant’s convictions and remanded for a new trial. (JORGENSEN and BIRKETT, concurring)