Illinois Supreme Court

People v. Brown

February 17, 2023466 Ill. Dec. 62

Summary

The court affirmed the defendant's armed habitual criminal conviction, holding that a defendant has no constitutional right to be present when counsel exercises juror challenges after the defendant attended voir dire. Because the record did not show that counsel failed to represent the defendant's interests, the defendant failed to establish deficient performance under the ineffective-assistance framework, and the court did not need to reach prejudice. The court also overruled contrary appellate authority recognizing a constitutional right to presence during juror-challenge conferences.