Strickland test in Illinois

2026“This ‘arguable’ Strickland test [(Strickland v. Washington, 466 U.S. 668 (1984))] demonstrates that first-stage postconviction petitions alleging ineffective assistance of counsel are judged by a lower pleading standard than are such petitions at the second stage of the proceeding.” Id. ¶ 20.

2026The failure to satisfy either prong of the Strickland test precludes a finding of ineffective assistance of [trial] counsel.” People v. Yankaway, 2025 IL 130207, ¶ 62 . ¶ 87 “The benchmark for judging any claim of ineffectiveness must be whether [trial] counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be 34 relied on as having produced a just result.” Strickland, 466 U.S. at 686 .

2026See People v. Albanese, 104 Ill. 2d 504, 526 (1984) (adopting the Strickland standard).

2026See People v. Albanese, 104 Ill. 2d 504, 526 (1984) (adopting the Strickland standard).

2026(Internal quotation marks omitted.) Carlisle, 2015 IL App (1st) 131144, ¶ 72 . “[A] reasonable probability that the result would have been different is a probability sufficient to undermine confidence in the outcome—or put another way, that counsel’s deficient performance rendered the result of the trial unreliable or fundamentally unfair.” People v. Evans, 209 Ill. 2d 194, 220 (2004). ¶ 77 To prevail, a defendant must satisfy both prongs of the Strickland test.

2026(Internal quotation marks omitted.) Carlisle, 2015 IL App (1st) 131144, ¶ 72 . “[A] reasonable probability that the result would have been different is a probability sufficient to undermine confidence in the outcome—or put another way, that counsel’s deficient performance rendered the result of the trial unreliable or fundamentally unfair.” People v. Evans, 209 Ill. 2d 194, 220 (2004). ¶ 77 To prevail, a defendant must satisfy both prongs of the Strickland test.

2026People v. Clendenin, 238 Ill. 2d 302, 317-18 (2010).

2026People v. Clendenin, 238 Ill. 2d 302, 317-18 (2010).

2025However, for purposes of the second prong of the Strickland standard, a defendant who has pleaded guilty “must show that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial.” Hill v. Lockhart, 474 U.S. 52, 59 (1985).

2025However, for purposes of the second prong of the Strickland standard, a defendant who has pleaded guilty “must show that there is a reasonable probability that, but for counsel’s errors, he would not have pleaded guilty and would have insisted on going to trial.” Hill v. Lockhart, 474 U.S. 52, 59 (1985).

2025“The failure to satisfy either the deficiency prong or the prejudice prong of the Strickland test precludes a finding of ineffective assistance of counsel.” People v. Enis, 194 Ill. 2d 361, 377 (2000). ¶ 40 For the same reasons we decline to apply the plain error doctrine, defendant cannot show he was prejudiced by counsel’s failure to investigate the exposure of the jury to the interview or move for a mistrial.

2025“The failure to satisfy either the deficiency prong or the prejudice prong of the Strickland test precludes a finding of ineffective assistance of counsel.” People v. Enis, 194 Ill. 2d 361, 377 (2000). ¶ 40 For the same reasons we decline to apply the plain error doctrine, defendant cannot show he was prejudiced by counsel’s failure to investigate the exposure of the jury to the interview or move for a mistrial.

2026People v. Coleman, 183 Ill. 2d 366, 397 (1998). “[I]t is not necessary to evaluate both prongs of the Strickland test if the defendant makes an insufficient showing on one.” People v. Waldrop, 2025 IL App (5th) 230085-U , ¶ 11. ¶ 17 Strategic decisions made by counsel are entitled to substantial deference.

2026People v. Coleman, 183 Ill. 2d 366, 397 (1998). “[I]t is not necessary to evaluate both prongs of the Strickland test if the defendant makes an insufficient showing on one.” People v. Waldrop, 2025 IL App (5th) 230085-U , ¶ 11. ¶ 17 Strategic decisions made by counsel are entitled to substantial deference.

2022People v. Patterson, 192 Ill. 2d 93, 107 (2000) (failure to satisfy either prong of the Strickland test precludes a finding of ineffective assistance of counsel). ¶ 64 Even if we were to assume counsel’s performance was deficient, defendant failed to demonstrate that he was arguably prejudiced by counsel’s performance by showing he would have been better off going to trial.

2022People v. Patterson, 192 Ill. 2d 93, 107 (2000) (failure to satisfy either prong of the Strickland test precludes a finding of ineffective assistance of counsel). ¶ 64 Even if we were to assume counsel’s performance was deficient, defendant failed to demonstrate that he was arguably prejudiced by counsel’s performance by showing he would have been better off going to trial.

2025“More specifically, a defendant must show that counsel’s performance was objectively unreasonable under prevailing professional norms and that there is a ‘reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.’ ” Id. (quoting Strickland v. Washington, 466 U.S. 668, 694 (1984)). “[A] defendant must establish both prongs of the Strickland test, such that the failure to establish either precludes a finding of ineffective assistance of counsel.” People v. Cherry, 2016 IL 118728, ¶ 31 .

2025“More specifically, a defendant must show that counsel’s performance was objectively unreasonable under prevailing professional norms and that there is a ‘reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.’ ” Id. (quoting Strickland v. Washington, 466 U.S. 668, 694 (1984)). “[A] defendant must establish both prongs of the Strickland test, such that the failure to establish either precludes a finding of ineffective assistance of counsel.” People v. Cherry, 2016 IL 118728, ¶ 31 .

2023For instance, in Pitsonbarger, our supreme court adopted the Strickland standard of prejudice for successive postconviction petitions, which was first articulated in People v. Flores, 153 Ill.2d 264 , 280 1992) (“Whether the seemingly narrower test of prejudice required in a Strickland analysis satisfies the requisite showing of prejudice under McCleskey is uncertain”), and reaffirmed that adoption in People v. Smith, 2014 IL 115946, ¶ 34 (“We analogized the cause-and-prejudice test in the context of a successive postconviction petition to the cause-and-prejudice test for ineffective assistanc

2023For instance, in Pitsonbarger, our supreme court adopted the Strickland standard of prejudice for successive postconviction petitions, which was first articulated in People v. Flores, 153 Ill.2d 264 , 280 1992) (“Whether the seemingly narrower test of prejudice required in a Strickland analysis satisfies the requisite showing of prejudice under McCleskey is uncertain”), and reaffirmed that adoption in People v. Smith, 2014 IL 115946, ¶ 34 (“We analogized the cause-and-prejudice test in the context of a successive postconviction petition to the cause-and-prejudice test for ineffective assistanc

2023“A defendant must satisfy both prongs of the Strickland test[,]” and a failure to establish either prong “ ‘will be fatal to the claim.’ ” Id. at 411 (quoting People v. Sanchez, 169 Ill. 2d 472, 487 (1996)). ¶ 37 Here, the sole argument presented on appeal claims that defendant has a right to effective counsel for pretrial hearings.

2023“A defendant must satisfy both prongs of the Strickland test[,]” and a failure to establish either prong “ ‘will be fatal to the claim.’ ” Id. at 411 (quoting People v. Sanchez, 169 Ill. 2d 472, 487 (1996)). ¶ 37 Here, the sole argument presented on appeal claims that defendant has a right to effective counsel for pretrial hearings.

2026“If either prong of the Strickland test is not met, defendant’s claim must fail.” People v. Perry, 224 Ill. 2d 312, 342 (2007). ¶ 35 Here, it is not necessary to determine whether the respective decisions of trial and appellate counsel fell below an objective standard of reasonableness because we agree with the State the evidence at trial was sufficiently overwhelming such that defendant cannot arguably show he was prejudiced. ¶ 36 First, defendant’s testimony at trial supported his conviction for AHC.

2026“If either prong of the Strickland test is not met, defendant’s claim must fail.” People v. Perry, 224 Ill. 2d 312, 342 (2007). ¶ 35 Here, it is not necessary to determine whether the respective decisions of trial and appellate counsel fell below an objective standard of reasonableness because we agree with the State the evidence at trial was sufficiently overwhelming such that defendant cannot arguably show he was prejudiced. ¶ 36 First, defendant’s testimony at trial supported his conviction for AHC.

2025“A defendant must satisfy both prongs of the Strickland test.” People v. Evans, 186 Ill. 2d 83, 94 (1999).

2025“A defendant must satisfy both prongs of the Strickland test.” People v. Evans, 186 Ill. 2d 83, 94 (1999).

2025(West 2022)).” Id. ¶ 161 Having concluded that Krankel counsel’s decision not to present all of a defendant’s nonfrivolous claims, on its own, does not constitute ineffective assistance of counsel, we next examine Krankel counsel’s and Morris’s representation under the usual Strickland standard—namely, “a defendant must show both that counsel’s performance was deficient and that the deficient performance prejudiced the defendant.” People v. Petrenko, 237 Ill. 2d 490, 496 (2010). ¶ 162 Because we conclude that Krankel counsel’s failure to raise defendant’s specific claims for ineffective assist

2025(West 2022)).” Id. ¶ 161 Having concluded that Krankel counsel’s decision not to present all of a defendant’s nonfrivolous claims, on its own, does not constitute ineffective assistance of counsel, we next examine Krankel counsel’s and Morris’s representation under the usual Strickland standard—namely, “a defendant must show both that counsel’s performance was deficient and that the deficient performance prejudiced the defendant.” People v. Petrenko, 237 Ill. 2d 490, 496 (2010). ¶ 162 Because we conclude that Krankel counsel’s failure to raise defendant’s specific claims for ineffective assist

2025“The failure to satisfy either prong of the Strickland test precludes a finding of ineffective assistance of counsel.” Id.

2025“The failure to satisfy either prong of the Strickland test precludes a finding of ineffective assistance of counsel.” Id.

2025The Strickland standard requires a defendant to “show that counsel’s performance fell below an objective standard of reasonableness and that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Id.

2025The Strickland standard requires a defendant to “show that counsel’s performance fell below an objective standard of reasonableness and that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Id.

2026People v. Cherry, 2016 IL 118728 , - 21 - ¶ 30 (citing Strickland v. Washington, 466 U.S. 668, 694 (1984)). “[T]o prevail on an ineffective assistance claim under Strickland, a defendant must establish both prongs of the Strickland test.” Cherry, 2016 IL 118728, ¶ 31 . ¶ 70 To establish that a defendant was prejudiced by counsel’s deficiencies, “[t]he defendant must show that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Strickland, 466 U.S. at 694 .

2026People v. Cherry, 2016 IL 118728 , - 21 - ¶ 30 (citing Strickland v. Washington, 466 U.S. 668, 694 (1984)). “[T]o prevail on an ineffective assistance claim under Strickland, a defendant must establish both prongs of the Strickland test.” Cherry, 2016 IL 118728, ¶ 31 . ¶ 70 To establish that a defendant was prejudiced by counsel’s deficiencies, “[t]he defendant must show that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Strickland, 466 U.S. at 694 .

2025People v. Richardson, 189 Ill. 2d 401, 411 (2000). “ ‘[A] court need not determine whether counsel’s performance was deficient before examining the prejudice suffered by the defendant was a result of the alleged deficiencies. *** If it is easier to dispose of an ineffectiveness claim on the ground of lack of sufficient prejudice, which we expect will often be so, that course should be followed.’ ” Albanese, 104 Ill. 2d at 527 (quoting Strickland, 466 U.S. at 697 ). ¶ 57 To establish deficiency under the first prong of the Strickland test, defendant must overcome the strong presumption that the

2025People v. Richardson, 189 Ill. 2d 401, 411 (2000). “ ‘[A] court need not determine whether counsel’s performance was deficient before examining the prejudice suffered by the defendant was a result of the alleged deficiencies. *** If it is easier to dispose of an ineffectiveness claim on the ground of lack of sufficient prejudice, which we expect will often be so, that course should be followed.’ ” Albanese, 104 Ill. 2d at 527 (quoting Strickland, 466 U.S. at 697 ). ¶ 57 To establish deficiency under the first prong of the Strickland test, defendant must overcome the strong presumption that the

2025Furthermore, the State argues that Blanks was specifically targeted not simply for drugs and money but because he was a drug dealer for a rival gang. ¶ 95 We reiterate the standard from above: to prevail under the Strickland standard, “a defendant must prove that defense counsel’s performance fell below an objective standard of reasonableness and that this substandard performance created a reasonable probability that, but for counsel’s errors, the result of the proceeding would have been different.” Graham, 206 Ill. 2d at 476 . ¶ 96 The evidence at trial showed defendant did have some level of

2025Furthermore, the State argues that Blanks was specifically targeted not simply for drugs and money but because he was a drug dealer for a rival gang. ¶ 95 We reiterate the standard from above: to prevail under the Strickland standard, “a defendant must prove that defense counsel’s performance fell below an objective standard of reasonableness and that this substandard performance created a reasonable probability that, but for counsel’s errors, the result of the proceeding would have been different.” Graham, 206 Ill. 2d at 476 . ¶ 96 The evidence at trial showed defendant did have some level of

2024“The failure to satisfy either prong of the Strickland test precludes a finding of ineffective assistance of counsel.” People v. Patterson, 217 Ill. 2d 407, 438 (2005). ¶ 62 To establish prejudice based on defense counsel’s decision not to file a motion to suppress evidence, a defendant must show there is a reasonable probability that (1) the trial court would have granted the motion, and (2) doing so would have altered the outcome.

2024“The failure to satisfy either prong of the Strickland test precludes a finding of ineffective assistance of counsel.” People v. Patterson, 217 Ill. 2d 407, 438 (2005). ¶ 62 To establish prejudice based on defense counsel’s decision not to file a motion to suppress evidence, a defendant must show there is a reasonable probability that (1) the trial court would have granted the motion, and (2) doing so would have altered the outcome.

2020Strickland v. Washington, 466 U.S. 668, 687 (1984); People v. Albanese, 104 Ill. 2d 504, 526 (1984) (adopting the Strickland standard in Illinois); People v. Caballero, 126 Ill. 2d 248, 269 (1989) (applying the Strickland standard to appellate counsel). ¶ 40 Counsel’s performance is deficient when it falls below “an objective standard of reasonableness.” Strickland, 466 U.S. at 688 .

2020Strickland v. Washington, 466 U.S. 668, 687 (1984); People v. Albanese, 104 Ill. 2d 504, 526 (1984) (adopting the Strickland standard in Illinois); People v. Caballero, 126 Ill. 2d 248, 269 (1989) (applying the Strickland standard to appellate counsel). ¶ 40 Counsel’s performance is deficient when it falls below “an objective standard of reasonableness.” Strickland, 466 U.S. at 688 .

2026In Cronic, a companion case to Strickland, the -7- Supreme Court “explained that prejudice may be presumed where (1) the defendant ‘is denied counsel at a critical stage,’ (2) counsel ‘entirely fails to subject the prosecution’s case to meaningful adversarial testing,’ or (3) counsel is called upon to represent a client in circumstances under which no lawyer could prove effective assistance.” Id. (quoting Cronic, 466 U.S. at 659-61 ). ¶ 23 Relevant to the instant appeal is the second exception to the Strickland test— namely, the failure “to subject the prosecution’s case to meaningful adversar

2026In Cronic, a companion case to Strickland, the -7- Supreme Court “explained that prejudice may be presumed where (1) the defendant ‘is denied counsel at a critical stage,’ (2) counsel ‘entirely fails to subject the prosecution’s case to meaningful adversarial testing,’ or (3) counsel is called upon to represent a client in circumstances under which no lawyer could prove effective assistance.” Id. (quoting Cronic, 466 U.S. at 659-61 ). ¶ 23 Relevant to the instant appeal is the second exception to the Strickland test— namely, the failure “to subject the prosecution’s case to meaningful adversar

2026To establish prejudice, the defendant must show, “absent counsel’s errors, there is a reasonable probability that the result of the proceeding would have been different.” Gilker, 2023 IL App (4th) 220914 , ¶ 77. ¶ 28 In deciding whether counsel was deficient, “[c]ourts must indulge a strong presumption that counsel’s conduct is sound trial strategy.” People v. Quezada, 2024 IL 128805, ¶ 60 (citing Strickland, 466 U.S. at 689 ). “ ‘A defendant must satisfy both prongs of the Strickland test and a failure to satisfy any one of the prongs precludes a finding of ineffectiveness.’ ” People v. Bradf

2026To establish prejudice, the defendant must show, “absent counsel’s errors, there is a reasonable probability that the result of the proceeding would have been different.” Gilker, 2023 IL App (4th) 220914 , ¶ 77. ¶ 28 In deciding whether counsel was deficient, “[c]ourts must indulge a strong presumption that counsel’s conduct is sound trial strategy.” People v. Quezada, 2024 IL 128805, ¶ 60 (citing Strickland, 466 U.S. at 689 ). “ ‘A defendant must satisfy both prongs of the Strickland test and a failure to satisfy any one of the prongs precludes a finding of ineffectiveness.’ ” People v. Bradf

2023Hattery’s ruling is to be narrowly construed and “defendant ‘faces a high burden before he can forsake the two-part Strickland test.’ ” People v. Horton, 143 Ill. 2d 11, 24 (1991) (quoting People v. Johnson, 128 Ill. 2d 253, 270 (1989)). ¶ 21 Defendant argues that posttrial counsel’s performance was so deficient that it falls into the Cronic/Hattery exception and thus, he is not required to meet the two-part Strickland test for ineffectiveness.

2023Hattery’s ruling is to be narrowly construed and “defendant ‘faces a high burden before he can forsake the two-part Strickland test.’ ” People v. Horton, 143 Ill. 2d 11, 24 (1991) (quoting People v. Johnson, 128 Ill. 2d 253, 270 (1989)). ¶ 21 Defendant argues that posttrial counsel’s performance was so deficient that it falls into the Cronic/Hattery exception and thus, he is not required to meet the two-part Strickland test for ineffectiveness.

2026People v. Houston, 226 Ill. 2d 135, 144 (2007). ¶ 49 “In unusual cases, the cumulative effect of numerous errors can create a pervasive pattern of unfair prejudice despite the fact that none of the errors, standing alone, would be serious enough to warrant consideration under the second prong” of the Strickland test.

2026People v. Houston, 226 Ill. 2d 135, 144 (2007). ¶ 49 “In unusual cases, the cumulative effect of numerous errors can create a pervasive pattern of unfair prejudice despite the fact that none of the errors, standing alone, would be serious enough to warrant consideration under the second prong” of the Strickland test.

2026Simpson, 2015 IL 116512, ¶ 35 . ¶ 82 Under either defendant’s (non-forfeited) argument that it was error not to give the appropriate jury instruction or his Strickland claim of ineffectiveness, our answer is the same: as the evidence against defendant was overwhelming, the absence of an instruction defining a “dangerous weapon” did not impact the outcome of the case in any measurable way.

2026“A defendant must satisfy both prongs of the Strickland test and a failure to satisfy any one of the prongs precludes a finding of ineffectiveness.” People v. Simpson, 2015 IL 116512 , ¶ 35. ¶ 19 To establish deficient performance, the defendant must show that his attorney’s performance fell below an objective standard of reasonableness.

2026“A defendant’s failure to establish either prong of the Strickland test precludes a finding of ineffective assistance of counsel.” Id.

2026“A defendant’s failure to establish either prong of the Strickland test precludes a finding of ineffective assistance of counsel.” Id.