People v. Campbell, 2015 IL App (3d) 130614

Christopher Campbell was indicted for aggravated criminal sexual assault and criminal sexual assault involving a mentally disabled victim.
Campbell initially waived a jury trial in writing, pled guilty (with a written plea that included a jury waiver), and received a 15-year cap recommendation; he later moved to withdraw that plea and the trial court granted the motion.
After plea withdrawal, Campbell pleaded to proceed with a stipulated bench trial in which the parties agreed the State’s proffered evidence was sufficient to convict.
At the stipulated bench trial the court admonished Campbell about several rights (right to a trial, to counsel, to cross-examine, to call witnesses, and that he would be waiving some rights) but did not explicitly tell him he had a right to a jury trial or that he would waive that right by agreeing to a stipulated bench trial.
The court found Campbell guilty after the stipulated evidence and sentenced him to 15 years; Campbell appealed, arguing the trial court failed to properly admonish him about his jury-trial right when the stipulated bench trial was tantamount to a guilty plea.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a stipulated bench trial tantamount to a guilty plea required Rule 402(a) admonitions that explicitly notify defendant of his jury-trial right and that stipulation waives it	State: prior jury-waiver admonitions and other admonitions were sufficient; defendant understood and knowingly waived jury right	Campbell: the stipulated bench trial was tantamount to a guilty plea and the court failed to admonish that he had a right to a jury trial and that he waived it by stipulating	Court: The admonishments before the stipulated bench trial were inadequate; because Campbell’s prior jury-waiver was withdrawn with his guilty plea, the jury right had to be reinstated and expressly admonished; conviction reversed and remanded.

Piatkowski, 225 Ill. 2d 551 (plain-error doctrine and standards) (discusses when unpreserved errors may be reviewed).
Bracey, 213 Ill. 2d 265 (defendant’s jury-right waiver at a prior proceeding does not automatically carry over; waiver must be knowingly made).
Walker, 109 Ill. 2d 484 (substantial compliance with admonitions is shown by record affirmatively demonstrating defendant’s understanding).
Culbertson, 162 Ill. App. 3d 319 (admonishing only ‘‘right to a hearing or trial’’ insufficient to show defendant knew of jury-trial right).
Dougherty, 394 Ill. App. 3d 134 (purpose of Rule 402 admonitions and standard of substantial compliance).
Bannister, 232 Ill. 2d 52 (plain-error review framework)