People v. Wood, 16 N.E.3d 253

Marilyn Wood was found bound, gagged, and fatally asphyxiated in her basement; her son Jonathan Wood was arrested after a high-speed chase and found with Marilyn’s documents and a forged note. He was tried in a bench proceeding and convicted of first‑degree murder and related offenses and sentenced to 64 years.
Pretrial competency and sanity evaluations occurred: Dr. Lourgos initially found Wood unfit and later fit with medication; multiple clinicians (including Drs. Lourgos, Nazareno, and Hanlon) diagnosed paranoid schizophrenia but post‑offense sanity opinions varied. Wood refused to submit to additional sanity testing.
At trial defense counsel asked for a guilty but mentally ill (GBMI) finding but did not formally raise the statutory insanity defense or call Dr. Hanlon to testify on sanity; the defense stipulated to medical findings and Wood testified. Dr. Hanlon later testified at sentencing that Wood had schizophrenia but was not legally insane at the time of the offense.
The trial court denied a GBMI finding, concluding the defense had not proved mental illness at the time of the offense by a preponderance; the court also found Wood not credible. Wood argued on appeal that trial counsel was ineffective for (1) seeking GBMI without asserting the required insanity defense, and (2) failing to call Dr. Hanlon to testify at trial about Wood’s mental illness at the time of the offense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for requesting GBMI without raising the statutory insanity defense	State: Claims forfeiture/invited error arguments; argues raising insanity would have made no practical difference to sentence	Wood: Counsel should have formally asserted insanity and presented expert testimony to secure GBMI and treatment	Court: Counsel not ineffective; GBMI would likely have been appropriate if insanity and expert testimony were presented, but counsel reasonably declined because no admissible evidence supported an insanity plea and ethical rules barred asserting an unsupported defense
Whether counsel was ineffective for not calling defense expert (Dr. Hanlon) at trial to testify about sanity at time of offense	State: Emphasizes that Dr. Hanlon’s sentencing testimony showed no unfair prejudice or different outcome	Wood: Failure to call Hanlon deprived him of a likely GBMI finding and statutory treatment	Court: Prejudice shown (GBMI would have yielded treatment), but no deficiency — Hanlon’s opinion was that Wood was not insane at the time, Wood refused additional exams, and counsel could not in good faith assert insanity without admissible supporting evidence

Strickland v. Washington, 466 U.S. 668 (1984) (two‑pronged ineffective assistance standard)
People v. Rainey, 149 Ill. App. 3d 327 (1986) (failure to assert insanity to obtain GBMI can be ineffective assistance where evidence supported it)
People v. Gosier, 145 Ill. 2d 127 (1991) (insanity defense required to be eligible for GBMI)
People v. Silagy, 101 Ill. 2d 147 (1984) (defendant must present some evidence to raise affirmative insanity defense)
People v. Thompson, 238 Ill. 2d 598 (2010) (plain‑error preservation rule discussed)
People v. Perry, 224 Ill. 2d 312 (2007) (deference to trial strategy in ineffective assistance review)
People v. Evans, 186 Ill. 2d 83 (1999) (strong presumption that counsel’s choices are strategic)