People v. Bates, 2019 IL 124143

Quentin Bates was tried for home invasion and aggravated criminal sexual conduct involving victim A.P.; charges from a separate incident involving C.H. were consolidated for pretrial purposes.
The State obtained a pretrial ruling admitting evidence of the C.H. assault as other-crimes evidence under 725 ILCS 5/115-7.3(b).
Bates retained private counsel for the A.P. trial only; the public defender remained counsel for the C.H. matter.
Defense counsel requested and received funding for a DNA expert to review testing (he said the request covered both victims) but during trial repeatedly stated he was not counsel for the C.H. case and had not reviewed much of the State’s C.H.-related evidence.
The jury convicted Bates; at the new-trial hearing defense counsel said he was "taken by surprise" at the depth of the C.H. evidence and would have sought independent review had he known. The trial court denied the new-trial motion.
The appellate court affirmed. The Illinois Supreme Court reviewed whether counsel’s statements required the court to conduct a Krankel inquiry into ineffective assistance of counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a trial court must hold a Krankel inquiry when defense counsel makes statements suggesting he failed to investigate/prepare (without a pro se claim).	The court should not be required to probe every defense counsel statement; Krankel is triggered only by a defendant’s pro se claim.	Counsel’s statements at the new-trial hearing admitting surprise/neglect as to the other-crimes evidence amount to an admission of ineffective assistance requiring a Krankel inquiry.	Krankel inquiry is not required unless the defendant himself (pro se) or counsel at the defendant’s clear direction raises the claim; trial court did not err.
Whether counsel’s statements here amounted to a clear admission of ineffective assistance requiring inquiry.	Same as above: the record does not compel inquiry; counsel’s comments reflect strategy and pretrial activity, not an unequivocal admission of neglect.	Counsel’s remarks were an admission of failure to investigate the C.H. evidence and thus required a Krankel hearing.	The court held counsel’s remarks did not trigger Krankel because Bates did not pro se raise ineffective-assistance and did not direct counsel to assert such a claim; no hearing required.

People v. Krankel, 102 Ill.2d 181 (establishing trial-court duty to inquire into pro se claims of ineffective assistance of counsel)
People v. Moore, 207 Ill.2d 68 (discussing standards for Krankel inquiries and what constitutes bringing a claim to the trial court)
People v. Banks, 237 Ill.2d 154 (noting that an oral motion can suffice to bring an ineffective-assistance claim to the court)
People v. Munson, 171 Ill.2d 158 (holding informal communications may alert the court to an ineffective-assistance claim)
People v. Sims, 167 Ill.2d 483 (distinguishing strategic decisions from claims warranting substitution of counsel or Krankel relief)
People v. Williams, 224 Ill. App.3d 517 (appellate decision treating trial counsel’s posttrial statements as triggering a Krankel inquiry)
People v. Hayes, 229 Ill. App.3d 55 (appellate decision holding counsel’s posttrial statements could require a Krankel hearing)