People v. Jocko, 239 Ill. 2d 87

Defendant Robert Jocko was charged with burglary for removing power tools valued over $300 on July 6, 2005 in Cook County.
Arraignment occurred August 25, 2005, with Assistant Public Defender Rosenthal; guilty plea not entered and a discovery motion was filed.
Nov 17, 2005, Mularski was appointed and filed a motion to quash arrest and suppress evidence; the motion was denied February 16, 2006.
On April 25, 2006, defendant filed a pro se Motion to Dismiss Based on Due Process Violation alleging counsel was not present at arraignment; the matter was not discussed on later dates.
September 6, 2006, Assistant Public Defender Fadell appeared; an affidavit signed by defendant regarding suppression and rights issues existed but the court was not shown to have addressed it.
Defendant was convicted in March 2007 and sentenced on April 6, 2007; appellate court remanded for an inquiry into ineffective assistance claims, which this Court later reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Krankel pretrial inquiry is required for pro se ineffective-assistance claims	State contends inquiry is unnecessary pretrial because prejudice cannot be evaluated prior to trial	Jocko argues Krankel applies pretrial to address claims of ineffective assistance before trial	Krankel pretrial inquiry not required; Strickland prejudice cannot be assessed pretrial

People v. Krankel, 102 Ill.2d 181 (1984) (established pretrial inquiry when defendant alleges ineffective assistance)
People v. Moore, 207 Ill.2d 68 (2003) (new counsel not automatically required; assess factual basis first)
Holloway v. Arkansas, 435 U.S. 475 (1978) (pretrial conflicts require remedy to protect right to counsel)
United States v. Cronic, 466 U.S. 648 (1984) (complete denial of counsel; pretrial assessment context)
Strickland v. Washington, 466 U.S. 668 (1984) (establishes prejudice standard for ineffective assistance)