People v. Hunt, 55 N.E.3d 1227

Jeffrey Hunt was charged with burglary and possession of burglary tools for allegedly stealing a car stereo and possessing a screwdriver; public defender appointed.
Multiple continuances occurred between Aug 2012 and Dec 2012; a substitute judge on Dec 12, 2012 recorded Hunt’s unequivocal request to represent himself and gave Faretta admonitions but deferred ruling to the trial judge.
On Dec 17, 2012 the trial judge denied Hunt’s renewed, unequivocal request to proceed pro se, characterizing it as a delay tactic; the court did not elicit further inquiry into Hunt’s reasons or make a knowing-intelligent-waiver finding.
Trial ultimately occurred July 30, 2013; eyewitness testimony and recovered stereo and screwdriver led to Hunt’s convictions on both counts.
Hunt was sentenced as a Class X offender (11 and 6 years concurrent) and appealed, arguing the court’s denial of self-representation required reversal; the court found that issue dispositive and reversed and remanded for a new trial.

Issue	Plaintiff's (State) Argument	Defendant's (Hunt) Argument	Held
Whether trial court erred by denying Hunt’s unequivocal request to proceed pro se	Request was untimely and made as gamesmanship/delay; court acted within discretion	Hunt unequivocally invoked Faretta right before trial; denial was arbitrary and without inquiry into knowing/intelligent waiver	Reversed: court abused discretion by denying pro se request as a delay tactic without proper inquiry
Forfeiture / plain-error review of self-rep claim	Hunt forfeited review by not raising objection in posttrial motion; plain-error not established	Claim involves structural error affecting entire trial so plain-error review appropriate	Court considered plain error due to structural nature and reversed on merits
Whether timing and circumstances justified denial as untimely or disruptive	Request was made on a day set for jury and when substitute judge sat; granting would disrupt schedule	Request was made before trial, not accompanied by request for continuance, and not obstructionist	Timing alone insufficient; request was timely because made before trial and not seeking extra preparation time
Whether retrial would violate double jeopardy	Retrial would violate double jeopardy if evidence insufficient at first trial	Hunt did not contest sufficiency	Court found evidence was sufficient to permit retrial; double jeopardy does not bar retrial

Faretta v. California, 422 U.S. 806 (U.S. 1975) (defendant has constitutional right to self-representation)
People v. Baez, 241 Ill. 2d 44 (Ill. 2011) (waiver of counsel must be knowing, intelligent, and unequivocal)
People v. Burton, 184 Ill. 2d 1 (Ill. 1998) (review of trial court’s denial of self-representation is for abuse of discretion)
People v. Rasho, 398 Ill. App. 3d 1035 (Ill. App. 2010) (day-of-trial pro se request denying was upheld where request was ambiguous and accompanied by implicit continuance request)
People v. Ward, 208 Ill. App. 3d 1073 (Ill. App. 1991) (pro se requests before trial are generally timely unless accompanied by a request for more preparation time)
People v. Fisher, 407 Ill. App. 3d 585 (Ill. App. 2011) (abuse of discretion standard and reversal where denial of Faretta right was arbitrary)