defendant claimed error in Illinois

2018See Taylor, 237 Ill. 2d at 77 , 927 N.E.2d at 1777 (finding a defendant’s statement, which could be subject to multiple interpretations, including regret over a rejected plea deal, was not sufficient to trigger a Krankel inquiry); King, 2017 IL App (1st) 142297, ¶ 20 , 80 N.E.3d 599 (finding the defendant was not entitled to Krankel inquiry when, at sentencing, the defendant claimed error in that a witness was not called without mentioning her attorney). ¶ 27 Here, defendant did not mention his attorney in his letter to the trial court.

2017See Taylor , 237 Ill. 2d at 77 , 340 Ill.Dec. 161 , 927 N.E.2d at 1777 (finding a defendant's statement, which could be subject to multiple interpretations, including regret over a rejected plea deal, was not sufficient to trigger a Krankel inquiry); King , 2017 IL App (1st) 142297 , ¶ 20, 414 Ill.Dec. 456 , 80 N.E.3d 599 (finding the defendant was not entitled to Krankel inquiry when, at sentencing, the defendant claimed error in that a witness was not called without mentioning her attorney). ¶ 27 Here, defendant did not mention his attorney in his letter to the trial court.

2014Id.

2014Id.

2010The court noted that the version of the Administrative Code in effect at the date of the offense stated, “ ‘A disinfectant that does not contain alcohol shall be used to clean the skin where a sample is to be collected.’ ” Bair, 379 Ill.

2010The court noted that the version of the Administrative Code in effect at the date of the offense stated, " 'A disinfectant that does not contain alcohol shall be used to clean the skin where a sample is to be collected.' " Bair, 379 Ill.

2009As described by the Chapman court: “The Prim instruction informs the jury of the requirement that the verdict be unanimous; that the jury has a duty to deliberate; that jurors must impartially consider the evidence; and that jurors should not hesitate to reexamine their views and change their opinions if they believe them to be erroneous, provided the change is not solely 16 1-07-3244 because of the opinion of fellow jurors or for the mere purpose of returning a verdict.” Chapman, 194 Ill. 2d at 222 , 743 N.E.2d at 70 .

2009As described by the Chapman court: “The Prim instruction informs the jury of the requirement that the verdict be unanimous; that the jury has a duty to deliberate; that jurors must impartially consider the evidence; and that jurors should not hesitate to reexamine their views and change their opinions if they believe them to be erroneous, provided the change is not solely 16 1-07-3244 because of the opinion of fellow jurors or for the mere purpose of returning a verdict.” Chapman, 194 Ill. 2d at 222 , 743 N.E.2d at 70 .

2026The defendant claimed that defense counsel did not sufficiently communicate in preparation for trial, and had not 1 See People v. Krankel, 102 Ill. 2d 181 (1984). 11 subpoenaed witnesses, and failed to question Albright about a cellphone video where she asserted that the defendant had nothing to do with the crime. ¶ 42 Defense counsel testified at the preliminary Krankel inquiry that he had met with the defendant several times and reviewed discovery with the defendant.

2021Further, although the State’s conduct in the case at bar is not nearly as pervasive as that of the prosecution’s in Powell, similar concerns expressed, particularly by the dissent in Powell, prevail here. ¶ 80 In Powell, the defendant claimed error in the trial court’s admission of evidence regarding a civil lawsuit brought by the defendant against the city of Stamford and the police officers who arrested him. 93 Conn. App. at 598 .

2020Id.

2012Id. at 843 . ¶ 18 As Dieterman explained, the trial court in that case had jurisdiction to enter the conviction that the defendant claimed was a violation of double jeopardy.

2012We explicitly stated that we could not review the defendant’s double jeopardy claim “unless [the] double jeopardy violation would render void the judgment on defendant’s guilty plea to the felony charge.” Id. at 841 .

2009Curry, 178 Ill. 2d at 516 .

1989After Cuyler, the supreme court of Illinois decided People v. Washington (1984), 101 Ill. 2d 104 , in which the defendant claimed a violation of his sixth amendment right to loyal counsel because he was represented in his Chicago murder trial, with his knowledge and approval, by an attorney who was also a prosecutor in Chicago Heights, whose police officers testified adversely to his interest at his pretrial motion to suppress which challenged the validity of his arrest by them.

1989After Cuyler , the supreme court of Illinois decided People v. Washington (1984), 101 Ill.2d 104 , in which the defendant claimed a violation of his sixth amendment right to loyal counsel because he was represented in his Chicago murder trial, with his knowledge and approval, by an attorney who was also a prosecutor in Chicago Heights, whose police officers testified adversely to his interest at his pretrial motion to suppress which challenged the validity of his arrest by them.

1987App. 2d 248, 249 , 269 N.E.2d 111 .) For example, in Kutella, the defendant claimed as error the fact that he was not proved to be of age 14 or upward, as the relevant rape statute required.

1981App. 3d 277 , 296 N.E.2d 621 , the defendant claimed error in permitting a minister to testify in violation of the clergyman’s privilege.

1978Once evidence tending to show insanity is introduced then the State has the burden of proving by the preponderance or greater weight of the evidence that the petitioner is sane.’ ” ( 44 Ill. 2d 376, 384 , 256 N.E.2d 321, 326 .) The defendant claimed that this instruction confused the jury by improperly stating that he had the burden of proving his insanity.

1978Once evidence tending to show insanity is introduced then the State has the burden of proving by the preponderance or greater weight of the evidence that the petitioner is sane.’ ” ( 44 Ill. 2d 376, 384 , 256 N.E.2d 321, 326 .) The defendant claimed that this instruction confused the jury by improperly stating that he had the burden of proving his insanity.