People v. Crutchfield, 2015 IL App (5th) 120371

Crutchfield was convicted of first-degree murder and sentenced to natural life in prison after a jury trial.
The victim was 6-year-old Ryon Smith; the body was found December 25, 2005 at the residence shared with Lohman and Crutchfield, Lohman being the victim’s mother and Crutchfield her boyfriend.
Autopsy showed blunt force trauma with mesenteric injury; defense argued epilepsy caused death, which the State rebutted with another pathologist.
During sentencing, Crutchfield raised ineffective assistance of counsel claims; the trial court conducted a Krankel-type inquiry and denied the claims as meritless, deeming them trial-strategy issues.
The trial court then applied a mandatory natural-life sentence under 5-8-1(a)(1)(c)(ii); Crutchfield moved to reconsider arguing the statute had been struck down and not reenacted, leading to a remand request on resentencing.
On appeal, the court affirmed the ineffective-assistance ruling but reversed and remanded to sentence without applying the mandatory life provision, citing Wooters and Quevedo as controlling and noting lack of reenactment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Appointment of counsel on ineffectiveness claim	Crutchfield contends counsel should have been replaced for posttrial ineffectiveness inquiry.	Crutchfield argues the trial court failed to appoint new counsel to investigate his ineffectiveness claim.	No reversible error; proper preliminary inquiry conducted, no manifest error
Effect of Wooters/Quevedo on mandatory life sentence	The mandatory life provision under 5-8-1(a)(1)(c)(ii) was void and not reenacted, requiring resentencing without it.	The statute had been reenacted; mandatory life sentence valid.	Remand for resentencing without the mandatory life provision; statute never validly reenacted

People v. Krankel, 102 Ill.2d 181 (1984) (requires limited inquiry into pro se ineffectiveness claims before appointing new counsel)
People v. Moore, 207 Ill.2d 68 (2003) (trial court must first determine basis of ineffectiveness before appointing new counsel)
People v. Leeper, 317 Ill. App.3d 475 (2000) (witness-witness credibility and trial strategy considerations in ineffectiveness claims)
People v. Albanese, 104 Ill.2d 504 (1984) (presumption of reasonable professional assistance in counsel's conduct)
People v. McCarter, 385 Ill. App.3d 919 (2008) (standard for reviewing trial court's decision on ineffectiveness claim)
People v. Fields, 2013 IL App (2d) 120945 (2013) (inquiry into ineffective-assistance claims may be flexible and non-formal)
People v. Wooters, 188 Ill.2d 500 (1999) (Public Act 89-203 unconstitutional under single-subject rule; life sentence invalid)
People v. Quevedo, 403 Ill. App.3d 282 (2010) (held that the life-sentence provision was void ab initio due to single-subject violation)
People v. Blair, 2013 IL 114122 (2013) (void-ab-initio doctrine and single-subject considerations; remedial reenactment requirements)
People v. Hauschild, 226 Ill.2d 63 (2013) (recall of unconstitutional proportionate penalties; remand may apply prior statute)
People v. Blair, 2013 IL 114122 (2013) (recited for single-subject remedy and reenactment principles)
Krankel, People v. Krankel (1984) (procedural framework for posttrial ineffectiveness claims)