People v. Bates, 2019 IL 124143

Quentin Bates was charged with home invasion and aggravated criminal sexual conduct arising from two separate assaults (victims A.P. and C.H.); charges were consolidated for pretrial proceedings.
Private counsel was retained to try the A.P. case; the public defender continued on the C.H. case. Counsel requested and obtained funds for an independent DNA expert to review testing for both victims.
At trial the State introduced other-crimes evidence concerning C.H.; the DNA evidence for C.H. was a full 16/16 loci match to Bates, while the DNA from A.P. matched Bates at 15/16 loci (a non‑direct match/exclusion issue).
Defense counsel repeatedly told the court and jury he was not Bates’s lawyer for the C.H. matter, cross‑examined few witnesses about C.H., and later argued at the new‑trial hearing that he was surprised by the depth of the State’s evidence and would have had it reviewed by defense experts if he had known.
The trial court denied the new‑trial motion; the appellate court affirmed. The Illinois Supreme Court addressed whether counsel’s statements obligated the trial court to conduct a Krankel inquiry into ineffective assistance of counsel.

Issue	People’s Argument	Bates’s Argument	Held
Whether counsel’s statements at the new‑trial hearing required a Krankel inquiry into ineffective assistance	No — Krankel is triggered by a defendant’s pro se claim (or counsel acting at the defendant’s direction); counsel’s remarks did not clearly raise an ineffective‑assistance claim on Bates’s behalf	Yes — counsel’s statements admitting surprise/neglect over other‑crimes evidence constituted an admission of ineffective assistance that required inquiry	Krankel inquiry not required: a claim must come from the defendant pro se or from counsel clearly stating he is raising the claim at the defendant’s direction
Whether trial courts must scrutinize counsel’s trial strategy/actions as potential Krankel triggers	That rule would be unworkable and force inquiry into privileged strategy; trial courts should not be required to probe every counsel statement	Courts should investigate when trial counsel’s posttrial statements amount to admissions of neglect	Court rejects a broad duty to investigate counsel statements and limits Krankel to pro se claims or counsel acting at defendant’s direction; overrules appellate authority to the contrary

People v. Krankel, 102 Ill. 2d 181 (1984) (trial court must inquire when defendant claims ineffective assistance)
People v. Moore, 207 Ill. 2d 68 (2003) (pro se defendant need only bring claim to court to trigger inquiry)
People v. Banks, 237 Ill. 2d 154 (2010) (oral motions can raise ineffective‑assistance claims)
People v. Ayres, 2017 Ill. 120071 (2017) (defendant need not provide detailed factual basis; claim must be clearly raised)
People v. Sims, 167 Ill. 2d 483 (1995) (strategic decisions by counsel generally do not entitle defendant to substitute counsel to argue ineffectiveness)
People v. Williams, 224 Ill. App. 3d 517 (1992) (appellate decision finding counsel’s statements sufficient to require Krankel hearing)
People v. Hayes, 229 Ill. App. 3d 55 (1992) (similar appellate holding)