People v. Dear

── People v. Dear ── Court: Appellate Court of Illinois Date: April 14, 2026 Category: General NOTICE 2026 IL App (4th) 250075-U FILED This Order was filed under Supreme Court Rule 23 and is April 14, 2026 not precedent except in the NO. 4-25-0075 Carla Bender th limited circumstances allowed 4 District Appellate under Rule 23(e)(1). IN THE APPELLATE COURT Court, IL OF ILLINOIS FOURTH DISTRICT THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) McLean County ROBERT CRAIGG DEAR, ) No. 24CF630 Defendant-Appellant. ) ) Honorable ) J. Jason Chambers, ) Judge Presiding. JUSTICE DeARMOND delivered the judgment of the court. Presiding Justice Steigmann and Justice Knecht concurred in the judgment. ORDER ¶1 Held: (1) The State proved defendant guilty beyond a reasonable doubt. (2) The trial court did not abuse its discretion in denying defendant’s request to continue his trial to obtain substitute counsel, who was not ready, willing, and able to appear. (3) Defendant’s trial counsel did not perform deficiently. (4) The trial court conducted an adequate inquiry into defendant’s pro se claims of ineffective assistance of counsel. ¶2 Defendant, Robert Craigg Dear, was convicted by a jury of (1) home invasion (720 ILCS 5/19-6(a)(2) (West 2024)), (2) criminal trespass to a residence (720 ILCS 5/19-4(a)(2) (West 2024)), and (3) battery (720 ILCS 5/12-3(a)(1) (West 2024)). On appeal, defendant argues his convictions for home invasion and criminal trespass to a residence should be reversed because the State did not prove him guilty beyond a reasonable doubt. He additionally argues he is entitled to a new preliminary inquiry pursuant to People v. Krankel, 102 Ill. 2d 181 (1984), because the trial court failed to conduct an adequate inquiry into his ineffective-assistance allegations and appoint new counsel. Finally, defendant contends the court deprived him of his right to counsel of his choice and that trial counsel rendered ineffective assistance. We affirm. ¶3 I. BACKGROUND ¶4 A. The State’s Charges ¶5 In June 2024, the State charged defendant with one count of home invasion (720 ILCS 5/19-6(a)(2) (West 2024)), one count of criminal trespass to a residence (720 ILCS 5/19- 4(a)(2) (West 2024)), and one count of battery (720 ILCS 5/12-3(a)(1) (West 2024)). ¶6 B. Jury Trial ¶7 1. Motion to Continue ¶8 Defendant’s jury trial commenced in September 2024. On the first day of the trial, defendant indicated he no longer wanted to be represented by his appointed counsel, claiming counsel was not affording him a “fair defense.” The trial court consulted with defense counsel, and counsel confirmed that he had reviewed the discovery materials, had spoken with defendant about the case, and was prepared for trial. Defendant, however, requested the court appoint different counsel until he