People v. Ayres
2017 IL 120071
| Ill. | 2018Background
- Qwantrell Ayres pleaded guilty to aggravated battery (Apr 2013); received 12-month conditional discharge and later stipulated he violated the condition by leaving the state.
- At sentencing (Sept 4, 2013) the court heard conflicting testimony about advice given by a non‑retained acquaintance attorney (McClellan) and sentenced Ayres to seven years.
- Ayres’s retained counsel filed a motion to reconsider; Ayres separately mailed a pro se posttrial petition to withdraw his guilty plea and vacate sentence alleging only “ineffective assistance of counsel.”
- The court held a hearing on counsel’s motion (Nov 4, 2013) without Ayres present and did not address or inquire into his pro se petition.
- The appellate court affirmed, holding the bare phrase “ineffective assistance of counsel” without factual detail was insufficient to trigger the trial court’s duty under Krankel to inquire.
- The Illinois Supreme Court granted review and held that a clear, posttrial pro se assertion of ineffective assistance, even without supporting facts, triggers the trial court’s duty to conduct a preliminary Krankel inquiry.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Ayres) | Held |
|---|---|---|---|
| Whether a bare, posttrial pro se allegation of "ineffective assistance of counsel" triggers the trial court's Krankel duty to inquire | Bare allegation insufficient; defendant must identify which attorney, when the alleged error occurred, and provide supporting facts | A clear posttrial claim, whether oral or written, is sufficient; defendant need only bring the claim to the court's attention for Krankel inquiry | Held: A clear posttrial pro se claim of ineffective assistance triggers a Krankel inquiry even without factual detail; remanded for preliminary inquiry |
Key Cases Cited
- People v. Krankel, 102 Ill. 2d 181 (establishes the common‑law procedure requiring trial courts to inquire into pro se posttrial ineffective‑assistance claims)
- People v. Moore, 207 Ill. 2d 68 (trial court must conduct some inquiry into the factual basis, if any, of a pro se ineffective‑assistance claim)
- People v. Banks, 237 Ill. 2d 154 (describes adequacy of the trial court's inquiry and permissible exchanges with counsel and defendant)
- People v. Taylor, 237 Ill. 2d 68 (discusses sufficiency of defendant's allegations and contrasts detailed versus conclusory claims)
- People v. Ramey, 152 Ill. 2d 41 (Krankel‑related authority on court duties)
- People v. Williams, 147 Ill. 2d 173 (Krankel‑related authority on trial court obligations)
- People v. Jocko, 239 Ill. 2d 87 (purpose of Krankel proceedings to create necessary record for appeal)