People v. Bates
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The prosecution alleged that on September 19, 2011, Bates entered A.P.’s home and, armed with a knife, sexually assaulted her; on October 6, 2011, he entered C.H.’s home, armed with a knife, and sexually assaulted her. The State elected to try him for the assault of A.P. first and moved to introduce other crimes evidence of the assault of C.H. (725 ILCS 5/115- 7.3(b)). After that motion was granted, Bates retained private counsel for the A.P. trial. The public defender continued to represent Bates regarding the C.H. assault. The court authorized payment for DNA testing and granted the defense a continuance but allowed C.H. to testify about her assault, despite a defense argument that counsel “couldn’t possibly do as good a job in defending my client since it wasn’t my case.” During closing argument, defense counsel asked the jury not to put much weight on the “case within a case,” stating that “[t]here’s been no review by any DNA experts.” The jury found Bates guilty. In an unsuccessful motion for a new trial, counsel claimed that he was surprised at the depth of the evidence introduced regarding the other crimes and that counsel would have had that evidence tested by his own experts had he known the depth.
The Illinois Supreme Court affirmed, rejecting an argument that counsel’s statements constituted an admission that he neglected Bates’s case, such that a Krankel hearing was warranted. A claim of ineffective assistance of counsel must come from the defendant. An attorney may raise his own ineffectiveness only if he does so clearly and at the defendant’s direction and informs the court that the defendant has instructed him to make such a claim.
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