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People v. Earnest Bell, 2018 IL App (4th) 151016 (

JURISDICTION The Fourth District ruled that it had jurisdiction over the appeal even though the trial court never disposed of defendant's pro se posttrial motion that included an explicit claim of ineffective assistance of counsel. Defendant's notice of appeal was not premature, because Supreme Court Rule 606(b) refers to motions filed "by counsel or by defendant, if not represented by counsel."

KRANKEL The Fourth District remanded for a preliminary inquiry because defendant's pro se posttrial motion was sufficient to trigger Krankel. The Fourth District declined to address defend...[More]

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