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9 Illinois opinions name it 1 courts 2017–2026 5 in the last five years
The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
People v. Taylorgreen2 sentences2025He also testified that he did not believe that his attorney could possibly be ready for trial within three days. ¶ 45 “If a defendant does not make a valid ineffective assistance claim, [he] does not trigger the need for the trial court to inquire.” People v. King, 2017 IL App (1st) 142297, ¶ 15 (citing People v. Taylor, 237 Ill. 2d 68, 75-77 (2010)). 2018“If a defendant does not make a valid ineffective assistance claim, [he] does not trigger the need for the trial court to inquire.” People v. King, 2017 IL App (1st) 142297, ¶ 15 , 80 N.E.3d 599 (citing People v. Taylor, 237 Ill. 2d 68 , 927 N.E.2d 1172 (2010)). | 4 | 6 |
People v. Kinggreen2 sentences2025He also testified that he did not believe that his attorney could possibly be ready for trial within three days. ¶ 45 “If a defendant does not make a valid ineffective assistance claim, [he] does not trigger the need for the trial court to inquire.” People v. King, 2017 IL App (1st) 142297, ¶ 15 (citing People v. Taylor, 237 Ill. 2d 68, 75-77 (2010)). 2025“If a defendant does not make a valid ineffective assistance claim, [he] does not trigger the need for the trial court to inquire.” People v. King, 2017 IL App (1st) 142297 , ¶ 15. | 1 | 4 |
People v. Mooregreen2 sentences2026See People v. Moore, 207 Ill. 2d 68, 78-79 (2003); see also People v. Thomas, 2017 IL App (4th) 150815, ¶ 24 (“If a defendant does not make a valid ineffective assistance claim, [he] does not trigger the need for the trial court to inquire.” (Internal quotation marks omitted.)); People v. Mourning, 2016 IL App (4th) 140270, ¶ 13 (“[A]n interchange with counsel or the defendant is not always necessary, as the trial court can base its evaluation *** on its knowledge of defense counsel’s performance at trial and the insufficiency of the defendant’s allegations on their face.” (Internal quotation 2017Id. at 78 . ¶ 15 If a defendant does not make a valid ineffective assistance claim, she does not trigger the need for the trial court to inquire. | 1 | 3 |
People v. Thomasgreen2 sentences2023“If a defendant does not make a valid ineffective assistance claim, [he] does not trigger the need for the trial court to inquire.” (Internal quotation marks omitted.) Thomas, 2017 IL App (4th) 150815, ¶ 24 . ¶ 63 Defendant acknowledges he did not use the words “ineffective assistance of counsel” in his October posttrial motion hearing testimony, but he nonetheless asserts that he alleged facts sufficient to trigger a preliminary Krankel hearing, namely that (1) he was coerced 18 into his plea agreement because his case was delayed and “nothing was moving forward,” (2) his plea attorney did no 2022“If a defendant does not make a valid ineffective assistance claim, [he] does not trigger the need for the trial court to inquire.” (Internal quotation marks omitted.) People v. Thomas, 2017 IL App (4th) 150815, ¶ 24 . -8- It would be, after all, a waste of time to question defense counsel or defendant about a pro se claim of ineffective assistance that self-evidently lacked legal merit. | 1 | 2 |
People v. Mourninggreen1 sentence2026See People v. Moore, 207 Ill. 2d 68, 78-79 (2003); see also People v. Thomas, 2017 IL App (4th) 150815, ¶ 24 (“If a defendant does not make a valid ineffective assistance claim, [he] does not trigger the need for the trial court to inquire.” (Internal quotation marks omitted.)); People v. Mourning, 2016 IL App (4th) 140270, ¶ 13 (“[A]n interchange with counsel or the defendant is not always necessary, as the trial court can base its evaluation *** on its knowledge of defense counsel’s performance at trial and the insufficiency of the defendant’s allegations on their face.” (Internal quotation | 1 | 1 |
People v. Bellgreen1 sentence2023People v. Bell, 2018 IL App (4th) 151016, ¶ 36 (citing People v. Taylor, 237 Ill. 2d 68, 75-76 (2010)). “[W]here the defendant’s claim is implicit and could be subject to different interpretations, a Krankel inquiry is not required.” Thomas, 2017 IL App (4th) 150815, ¶ 26 (citing Taylor, 237 Ill. 2d at 77 ). ¶ 65 On defendant’s first claim—that he was coerced into his plea agreement because his case was delayed and “nothing was moving forward”—we need only examine the record on appeal to see that defendant’s case was ready for jury trial on February 24, 2020, the same day his negotiated plea a | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
People v. Jolly
green
2 sentences2018“The issue of whether the circuit court properly conducted a preliminary Krankel inquiry presents a legal question that we review de novo.” People v. Jolly, 2014 IL 117142, ¶ 28 , 25 N.E.3d 1127 . ¶ 25 In this case, defendant wrote a letter to the trial court after sentencing, which stated, in part: “I would also like a motion filed for a reduction of sentence. 2018“The issue of whether the circuit court properly conducted a preliminary Krankel inquiry presents a legal question that we review de novo.” People v. Jolly, 2014 IL 117142, ¶ 28 , 25 N.E.3d 1127 . ¶ 25 In this case, defendant wrote a letter to the trial court after sentencing, which stated, in part: “I would also like a motion filed for a reduction of sentence. | 2 | 2017–2018 |
People v. Washington
green
1 sentence2025“Mere awareness by a trial court that defendant has complained of counsel’s representation imposes no duty on the trial court to sua sponte investigate defendant’s complaint ***.” People v. Washington, 2015 IL App (1st) 131023, ¶ 11 . ¶ 46 The trial court did not indicate that the defendant’s complaints about his attorney warranted a Krankel hearing (People v. Krankel, 102 Ill. 2d 181 (1984)); nevertheless, the trial court addressed the defendant’s complaints during the July 5, 2023, hearing. | 1 | 2025–2025 |
People v. Krankel
green
1 sentence2025“Mere awareness by a trial court that defendant has complained of counsel’s representation imposes no duty on the trial court to sua sponte investigate defendant’s complaint ***.” People v. Washington, 2015 IL App (1st) 131023, ¶ 11 . ¶ 46 The trial court did not indicate that the defendant’s complaints about his attorney warranted a Krankel hearing (People v. Krankel, 102 Ill. 2d 181 (1984)); nevertheless, the trial court addressed the defendant’s complaints during the July 5, 2023, hearing. | 1 | 2025–2025 |
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.