Background

• Ryan Roddis was convicted after a 2013 bench trial of aggravated domestic battery and sentenced to six years. The victim testified Roddis pushed her head into a door causing a laceration; Roddis said a thrown seat cushion caused the injury and he did not intend to harm her.
• After conviction Roddis filed a pro se posttrial motion (styled as a motion to reduce sentence) alleging ineffective assistance of trial counsel, principally that counsel failed to impeach the victim with text messages and that prior counsel misled him into waiving a jury.
• The trial court initially denied the pro se motion as untimely; on direct appeal the appellate court affirmed the conviction but remanded for a Krankel hearing to address the ineffective-assistance allegations.
• On remand the trial court conducted a preliminary Krankel inquiry (with defendant and his former counsel present), allowed defense counsel to respond, and concluded the pro se claims were meritless or trial-strategy matters, declining to appoint new counsel for a further Krankel hearing.
• The appellate court reversed, holding the trial court should have limited the preliminary inquiry to factual sufficiency and appointed new counsel if there was possible neglect; the Illinois Supreme Court granted review.
• The Illinois Supreme Court held the trial court did not err: at the preliminary Krankel stage a trial court may consider both factual and legal merits of pro se ineffective-assistance claims and may deny appointment of new counsel when claims are patently meritless.

Issues

Key Cases Cited

• People v. Krankel, 102 Ill.2d 181 (Ill. 1984) (established the common-law procedure for court inquiry into pro se ineffective-assistance claims)
• People v. Moore, 207 Ill.2d 68 (Ill. 2003) (trial court must examine factual basis of pro se ineffective-assistance claim; new counsel not automatic)
• People v. Chapman, 194 Ill.2d 186 (Ill. 2000) (trial court may find pro se claims frivolous on the record and deny appointment where allegations have no merit)
• People v. Coleman, 158 Ill.2d 319 (Ill. 1994) (trial court may conclude pro se claims are spurious when the court has firsthand knowledge showing no basis)
• People v. Johnson, 159 Ill.2d 97 (Ill. 1994) (illustrative discussion of reasons a court may find a pro se ineffectiveness claim lacks merit)
• People v. Jocko, 239 Ill.2d 87 (Ill. 2010) (describing Krankel’s role in narrowing issues and encouraging trial-court resolution of pro se claims)
• People v. Simms, 168 Ill.2d 176 (Ill. 1995) (noting new counsel unnecessary where claim is meritless)
• People v. Sims, 167 Ill.2d 483 (Ill. 1995) (same)