People v. Washington, 36 N.E.3d 440

Defendant Kenneth Washington was charged with possession of a controlled substance with intent to deliver after officers stopped his car and recovered 12 small bags of crack cocaine from a Mike and Ike candy box on the center console.
At bench trial, officers testified consistently; the court found them credible and convicted Washington of possession of a controlled substance (total estimated weight 2.3 grams; 8 bags tested positive for cocaine).
After conviction and before sentencing, defendant orally stated during allocution that he wanted to "file a verbal motion for ineffective assistance of counsel," but the court told him motions must be in writing and focused on requiring a written filing.
Defendant explained he lacked access to the law library and therefore could not prepare a written motion; after the court reiterated the writing requirement, defendant said he would withdraw the motion and the court proceeded to sentence him to 2½ years’ imprisonment.
On appeal, Washington did not challenge guilt or sentence; he argued the trial court erred by failing to conduct a Krankel preliminary inquiry into his pro se posttrial claim of ineffective assistance of counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by failing to conduct a Krankel inquiry into defendant's oral posttrial ineffective-assistance claim	The court adequately rejected the claim when it observed counsel "was anything but ineffective" and defendant voluntarily withdrew the motion	Defendant argued his oral statement at allocution was enough to invoke Krankel and the court prevented him from explaining the factual basis by insisting on a written motion he could not prepare	Reversed and remanded for a limited Krankel inquiry; the court erred by focusing on a written-filing requirement and not eliciting the factual basis of the claim
Whether defendant waived the claim by withdrawing the motion	The State contended defendant voluntarily withdrew and invited error by proceeding	Defendant contended the withdrawal resulted from the court’s erroneous insistence on a written filing and lack of library access	No waiver; court’s statements effectively compelled withdrawal and thus did not bar appellate review

People v. Krankel, 102 Ill. 2d 181 (trial court must inquire into pro se posttrial ineffective-assistance claims)
People v. Moore, 207 Ill. 2d 68 (trial court should examine factual basis of pro se claim and determine need for further inquiry or counsel)
People v. Cunningham, 376 Ill. App. 3d 298 (minimum factual specificity required to trigger Krankel inquiry)
People v. Bobo, 375 Ill. App. 3d 966 (pleading requirements for pro se ineffective-assistance claims are relaxed but not absent)
People v. Taylor, 237 Ill. 2d 68 (standard of review for Krankel issues is de novo)
People v. Carter, 208 Ill. 2d 309 (doctrine of invited error explained)