Illinois Supreme Court Holds “Bare Bones” Post-trial Pro-SE Assertion of Ineffective Assistance of Counsel Triggers a Krankel Inquiry on the Part of the Trial Court.

The Illinois Supreme Court was reviewing a case where a defendant, after trial, made a bare bones complaint of ineffective assistance of counsel. The trial court made no inquiries of defense counsel, and denied the motion as insufficient.

The Illinois Supreme Court resolves a number of conflicts among the appellate courts, holding that when there’s a claim on ineffective assistance, the trial court must conduct a Krankel inquiry.

The case is People v. Ayres.

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