In re Johnathan T., 2022 IL 127222

Johnathan T., a minor, was adjudicated delinquent in Massac County for 10 counts of aggravated criminal sexual assault involving a seven‑year‑old victim; court ordered SIR and a sex‑offender evaluation prior to disposition.
During the evaluator’s interview (included in the SIR), Johnathan told the evaluator his lawyer "does not answer calls," "we don’t talk," and "I’m never prepared for the stand."
The circuit court reviewed the SIR and sex‑offender evaluation, sentenced Johnathan to the Department of Juvenile Justice, and he appealed arguing the court failed to inquire into his pro se claim of ineffective assistance of counsel.
The appellate court affirmed, holding the statements in the sex‑offender evaluation were too vague to trigger a Krankel inquiry but recognized Krankel applies in delinquency cases.
The Illinois Supreme Court granted leave, held (1) the Krankel procedure applies in juvenile delinquency proceedings, (2) it applies to retained as well as appointed counsel, and (3) Johnathan’s statements in the court‑ordered reports constituted a clear claim that triggered a preliminary Krankel inquiry; the matter was remanded for that inquiry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the Krankel procedure apply in juvenile delinquency proceedings?	Krankel should apply; juveniles have a constitutional right to effective counsel.	State did not contest application in principle.	Yes—Krankel applies in juvenile delinquency cases.
Does Krankel apply when defendant is represented by retained counsel?	Krankel still applies; retained counsel can be ineffective and juveniles may not be able to seek new counsel.	Pecoraro suggests Krankel may not apply to privately retained counsel; court cannot force change of retained counsel.	Krankel applies to retained and appointed counsel.
Did Johnathan’s statements in the sex‑offender evaluation/SIR trigger a preliminary Krankel inquiry?	His statements (“we don’t talk,” “he does not answer calls,” “I’m never prepared”) were a clear pro se claim of ineffective assistance and were presented to the court.	Statements were vague, buried in evaluation, and not an explicit request for new counsel; thus insufficient to trigger Krankel.	Statements were sufficient; memorialization in court‑ordered reports that the court read triggered a Krankel inquiry.
Remedy/remand	Vacatur and remand for Krankel inquiry and any further proceedings as appropriate.	Circuit court judgment should be affirmed.	Circuit court’s adjudication affirmed in part but reversed in part; remanded to conduct a preliminary Krankel inquiry.

People v. Krankel, 102 Ill.2d 181 (establishes procedure for trial court inquiry into pro se claims of ineffective assistance)
People v. Pecoraro, 144 Ill.2d 1 (discusses limits on court interference with defendant’s choice of retained counsel)
People v. Moore, 207 Ill.2d 68 (defendant need only bring claim to court’s attention to trigger Krankel)
In re Gault, 387 U.S. 1 (juveniles have right to counsel; proceedings comparable in seriousness to felony prosecution)
Cuyler v. Sullivan, 446 U.S. 335 (retained counsel entitled to same Sixth Amendment protections as appointed counsel)
People v. Jackson, 2020 IL 124112 (clarifies that an oral or written pro se claim triggers Krankel)
People v. Ayres, 2017 IL 120071 (Krankel inquiry can be triggered by various forms of notice to the trial court)