People v. Reed, 48 N.E.3d 290

Defendant Antonio Reed was charged with delivery of a controlled substance after undercover and uniformed officers observed transactions in which Reed dropped a baggy that a co-defendant retrieved and completed a sale of heroin for $10.
Reed was represented by appointed counsel; counsel twice requested a bench trial in Reed's presence and Reed signed a written jury-waiver form on the day of trial.
At the start of the bench trial the court confirmed with Reed that he signed the waiver, that no one forced or promised him anything, and that his decision was voluntary; Reed answered in the affirmative.
The trial court convicted Reed after a bench trial and sentenced him to nine years' imprisonment, imposing various statutory assessments (Court System fee, State’s Attorney Records Automation fee, Public Defender Records Automation fee).
On appeal Reed argued (1) his jury waiver was not knowingly and voluntarily made and (2) three assessments were actually fines subject to a $5/day presentence custody credit; the appellate court affirmed and corrected the fines/fees order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of jury waiver	Waiver was knowing: counsel repeatedly requested bench trial and defendant signed waiver and affirmed questions in court.	Waiver was not knowing; court failed to explain nature/ramifications and difference between bench and jury trial.	Waiver was knowing and voluntary based on counsel's repeated bench requests, signed waiver, on-the-record colloquy, and defendant's extensive criminal history.
Classification of three assessments for presentence credit	Court System fee conceded to be a fine; Records Automation fees are compensatory fees (not subject to per‑day credit).	The three assessments are fines and therefore subject to $5/day presentence custody credit.	Court System fee is a fine (credit $50). State's Attorney and Public Defender Records Automation assessments are fees (no per‑day credit). Final corrected balance ordered.

Bracey v. People, 213 Ill. 2d 265 (Ill. 2004) (waiver must be made knowingly in open court; prior waiver does not automatically carry to a retrial)
Bannister v. People, 232 Ill. 2d 52 (Ill. 2008) (no specific admonition required; assessment of waiver depends on facts and whether defendant understood judge—not jury—would decide the case)
Sebag v. People, 110 Ill. App. 3d 821 (Ill. App. Ct. 1982) (pro se defendant unfamiliar with courts may not knowingly waive jury merely by signing waiver)
Castleberry v. State, 2015 IL 116916 (Ill. 2015) (addresses forfeiture and postconviction challenges to sentencing issues)
Jones v. People, 223 Ill. 2d 569 (Ill. 2006) (distinguishes fees as compensatory vs. fines as punitive)
Graves v. People, 235 Ill. 2d 244 (Ill. 2009) (classification of assessments depends on substance, not label)