People v. Yankaway

Summary

The Illinois Supreme Court affirmed Yankaway’s convictions and sentence, holding that counsel was not ineffective for failing to invoke the intrastate detainers statute because the applicable speedy-trial period began automatically under the statutory provision governing multiple pending charges. Although counsel performed deficiently by agreeing to a lengthy continuance, Yankaway could not establish Strickland prejudice, and the circuit court did not abuse its discretion in attributing the delay to him. The court also held that the sentencing misstatement was not plain error because it did not influence the sentence, and vacated the appellate court’s remand for sentencing on the unlawful-possession conviction.