People v. Ames, 2012 IL App (4th) 110513

Defendant Ames was charged with 0.08% DUI (count I) and DUI (count II); he pleaded guilty to count II and received one year of supervision with a DUI assessment and alcohol treatment condition.
State filed a petition to revoke supervision in Oct. 2010; Tippey then Lozier were appointed to represent him at different times due to disputes.
Tippey withdrew; Lozier was appointed but also sought to withdraw; defendant expressed dissatisfaction with both attorneys.
Court permitted Lozier to withdraw; defendant indicated he would represent himself or obtain counsel; court offered a continuance to hire counsel.
May 2011 revocation hearing: defendant again could not hire counsel; court denied further continuances and required self-representation.
Trial court found violation of supervision terms and resentenced; defendant appealed claiming improper Rule 401(a) admonishments and improper $500 DUI fine; reverse and remand for new revocation hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Rule 401(a) admonition provided before self-representation at the May 2011 hearing?	Ames argues admonitions were inadequate or omitted, invalidating pro se proceeding.	Ames contends he could not knowingly waive counsel without proper admonitions.	Remand for new revocation hearing; improper self-representation process.
Did the court properly impose the $500 DUI fine on remand?	Fine authorized by statute based on the prior conviction.	Fine not authorized since BAC did not meet 0.16 threshold.	Not reached on remand; remand for new hearing makes it moot.

Gallagher v. Lenart, 226 Ill. 2d 208 (2007) (waiver of counsel requires knowing, voluntary relinquishment with proper admonitions)
People v. Blair, 215 Ill. 2d 427 (2005) (distinguishes waiver and forfeiture of counsel; emphasizes admonitions)
People v. Williams, 92 Ill. 2d 109 (1982) (limits on forcing self-representation when a defendant has shown effort to obtain counsel)