2026 IL App (5th) 230792 No. 2026 IL App (5th) 230792
Rule 23 · Criminal —Criminal Procedure
- ¶1 Fifth District found multiple trial errors—faulty jury instruction, pretrial-order violation, and hearsay—but affirmed conviction due to strong unimpeached eyewitness testimony.
- ¶2 Court held defense counsel's cumulative failures to object satisfied Strickland's deficiency prong, but no prejudice existed given overwhelming evidence of guilt.
- ¶3 Useful for criminal defense and appellate attorneys litigating ineffective assistance claims, plain-error review, and cumulative error doctrine where multiple trial errors occurred but eyewitness evidence was strong.
2026 IL App (1st) 240772 No. 2026 IL App (1st) 240772
Rule 23 · Criminal —Criminal Procedure
- ¶1 Court affirms denial of postconviction relief where defendant gave shifting, inconsistent alibi accounts undermining witness credibility.
- ¶2 Counsel cannot be deemed ineffective for failing to investigate alibi witnesses the attorney was never told about.
- ¶3 Useful for criminal appellate practitioners litigating third-stage postconviction hearings, ineffective assistance claims, and judicial bias challenges.
2026 IL App (5th) 240274 No. 2026 IL App (5th) 240274
Rule 23 · Criminal —Criminal Procedure
- ¶1 Ineffective assistance claim fails where record shows no reliance on inadmissible evidence and other competent evidence supported the verdict.
- ¶2 Preliminary Krankel inquiry needs no set format; court may rely on colloquy with defendant, counsel, and its own trial knowledge.
- ¶3 Useful for criminal defense and appellate attorneys litigating Strickland prejudice arguments and preliminary Krankel inquiry adequacy in Illinois bench trials.