absence of plain error in Illinois

1991(Ill.Rev.Stat. 1983, ch. 38, par. 116-1.)" (Emphasis in original.) ( Enoch, 122 Ill.2d at 187 , 119 Ill.Dec. 265 , 522 N.E.2d 1124 .) This statutory requirement was in effect at the time of defendant's trial in November 1983, as was this court's holding in People v. Pickett (1973), 54 Ill.2d 280 , 296 N.E.2d 856 , that the failure to specify grounds for a new trial in a written motion for a new trial constitutes waiver of the issue on review in the absence of plain error.

1991Stat. 1983, ch. 38, par. 116—1.)” (Emphasis in original.) (Enoch, 122 Ill. 2d at 187 .) This statutory requirement was in effect at the time of defendant’s trial in November 1983, as was this court’s holding in People v. Pickett (1973), 54 Ill. 2d 280 , that the failure to specify grounds for a new trial in a written motion for a new trial constitutes waiver of the issue on review in the absence of plain error.

2025People v. Albea, 2017 IL App (2d) 150598, ¶ 16 .

2022People v. Albea, 2017 IL App (2d) 150598, ¶ 16 .

2025Ordinarily, under the standard set forth in Strickland v. Washington, 466 U.S. 668 (1984), “[t]o succeed on a claim of ineffective assistance of counsel, a defendant must show (1) counsel’s performance fell below an objective standard of reasonableness and (2) the deficient performance resulted in prejudice.” People v. Beasley, 2017 IL App (4th) 150291, ¶ 26 .

2025Ordinarily, under the standard set forth in Strickland v. Washington, 466 U.S. 668 (1984), “[t]o succeed on a claim of ineffective assistance of counsel, a defendant must show (1) counsel’s performance fell below an objective standard of reasonableness and (2) the deficient performance resulted in prejudice.” People v. Beasley, 2017 IL App (4th) 150291, ¶ 26 .

2000People v. Sommerville, 193 Ill.

1994See Enoch, 122 Ill.2d 176 , 119 Ill.Dec. 265 , 522 N.E.2d 1124 ; People v. Jones (1975), 60 Ill.2d 300, 309 , 325 N.E.2d 601 . *451 As defendant's last challenge to the trial proceedings, he contends that he was denied effective assistance because his counsel failed to object to, or preserve in his posttrial motion, various alleged errors during jury selection, trial and sentencing.

1994See Enoch, 122 Ill. 2d 176 ; People v. Jones (1975), 60 Ill. 2d 300, 309 .

1992(People v. Whitehead (1987), 116 Ill. 2d 425 , 508 N.E.2d 687 .) The evidence in this case came from sources other than an isolated test result.

1992(People v. Whitehead (1987), 116 Ill. 2d 425 , 508 N.E.2d 687 .) The evidence in this case came from sources other than an isolated test result.

1991(People v. Stewart (1984), 105 Ill. 2d 22 .) Defendant maintains that because he is challenging the sufficiency of the evidence used to convict him, his failure to raise the argument in his post-trial motion does not result in a waiver.

1990In People v. Nevitt (1990), 135 Ill. 2d 423, 448 , 553 N.E.2d 368, 377-78 , the supreme court stated — as it frequently has — that in order to preserve an issue for, review, a defendant must raise it in his post-trial motion; otherwise, in the absence of plain error, the issue is waived.

1990In People v. Nevitt (1990), 135 Ill. 2d 423, 448 , 553 N.E.2d 368, 377-78 , the supreme court stated — as it frequently has — that in order to preserve an issue for, review, a defendant must raise it in his post-trial motion; otherwise, in the absence of plain error, the issue is waived.

1990We further note that in the absence of plain error, a nonjurisdictional question, such as the consideration of an improper factor in aggravation, which is not raised in the trial court may not be presented for the first time on review. ( People v. Montague (1986), 149 Ill.

1990(People v. Montague (1986), 149 Ill.

1989People v. Enoch (1988), 122 Ill. 2d 176, 187 , 522 N.E.2d 1124 ; People v. Szabo (1986), 113 Ill. 2d 83, 93 , 497 N.E.2d 995 , cert. denied (1987), 479 U.S. 1101 , 94 L.

1989People v. Enoch (1988), 122 Ill. 2d 176, 187 , 522 N.E.2d 1124 ; People v. Szabo (1986), 113 Ill. 2d 83, 93 , 497 N.E.2d 995 , cert. denied (1987), 479 U.S. 1101 , 94 L.

1989People v. Enoch (1988), 122 Ill. 2d 176, 187 , 522 N.E.2d 1124 ; People v. Szabo (1986), 113 Ill. 2d 83, 93 , 497 N.E.2d 995 , cert. denied (1987), 479 U.S. 1101 , 94 L.

1989(Emphasis in original.) People v. Enoch (1988), 122 Ill.2d 176, 186, 187 , 522 N.E.2d 1124 , cert. denied (1988), ___ U.S. ___, 102 L.Ed.2d 263 , 109 S.Ct. 274 .

1989(Emphasis in original.) People v. Enoch (1988), 122 Ill. 2d 176, 186, 187 , 522 N.E.2d 1124 , cert. denied (1988), _U.S__, 102 L.

1989(Emphasis in original.) People v. Enoch (1988), 122 Ill.2d 176, 186, 187 , 522 N.E.2d 1124 , cert. denied (1988), ___ U.S. ___, 102 L.Ed.2d 263 , 109 S.Ct. 274 .

1988(Brown v. Decatur Memorial Hospital (1980), 83 Ill. 2d 344 , 415 N.E.2d 337 .) In criminal cases, both an objection at trial and a written post-trial motion raising the same issue are required to avoid waiver in the absence of plain error.

1988(Brown v. Decatur Memorial Hospital (1980), 83 Ill. 2d 344 , 415 N.E.2d 337 .) In criminal cases, both an objection at trial and a written post-trial motion raising the same issue are required to avoid waiver in the absence of plain error.

1986In the absence of plain error (People v. Friesland (1985), 109 Ill. 2d 369 , 488 N.E.2d 261 ), a nonjurisdictional question which was not presented in the trial court may not be presented for the first time upon review.

1986In the absence of plain error (People v. Friesland (1985), 109 Ill. 2d 369 , 488 N.E.2d 261 ), a nonjurisdictional question which was not presented in the trial court may not be presented for the first time upon review.

1986(People v. Amerman (1971), 50 Ill. 2d 196 , 279 N.E.2d 353 .) This rule has been applied to objections to sentencing procedures, and thus failure to object to a sentence or procedure during which it was imposed will constitute a waiver.

1986(People v. Amerman (1971), 50 Ill. 2d 196 , 279 N.E.2d 353 .) This rule has been applied to objections to sentencing procedures, and thus failure to object to a sentence or procedure during which it was imposed will constitute a waiver.

1983People v. Pickett (1973), 54 Ill.2d 280 , 296 N.E.2d 856 ; People v. Baske (1978), 66 Ill.

1983People v. Pickett (1973), 54 Ill. 2d 280 , 296 N.E.2d 856 ; People v. Baske (1978), 66 Ill.

1983People v. Boclair (1982), 106 Ill.

1977(People v. Scott (1972), 52 Ill. 2d 432 , 288 N.E.2d 478 .) Thus, notwithstanding the absence of an abuse of judicial discretion in denying the severance, the defendants’ subsequent failure to object to the admission of the statement into evidence effectively waives their raising the issue now.

1977(People v. Scott (1972), 52 Ill. 2d 432 , 288 N.E.2d 478 .) Thus, notwithstanding the absence of an abuse of judicial discretion in denying the severance, the defendants’ subsequent failure to object to the admission of the statement into evidence effectively waives their raising the issue now.

1975This point has been raised before in Illinois, and it is the rule in this State that “where an indictment contains several counts arising out of a single transaction, and a general verdict is returned, the effect is that the defendant is guilty as charged in each count, and if the punishment imposed.is one which is authorized to be inflicted for the offense charged in any one or more of the counts, the verdict must be sustained.” (People v. Lymore (1962), 25 Ill.2d 305, 308 .) We also note that no objection was made to the forms of verdict used, nor was any other form submitted by the defendan

1975People v. Green (1963), 27 Ill.2d 39, 44 .