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328 Ill. App. 3d 428

766 N.E.2d 311

262 Ill.Dec. 691

People v. Cleer

Appellate Court of Illinois

Decided March 14, 2002

Appellate Court of Illinois · decided 2002-03-14

Relies on 178 Ill. 2d 65 - People v. Griffin

Good law ✅— No negative treatment on recordhow we know

Decided 2002-03-14

How this case has been cited

Cited by 17 later decisions — most recently January 2026

17 state decisions

100200220102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

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PRESIDING JUSTICE LYTTON,

¶1specially concurring:

¶2Although defendant’s counsel withdrew his request for further hearing on the matter, he never withdrew his motion for hearing. Counsel seemed to be asking the court for a decision on fitness at the hearing on his speedy-trial motion. The trial court then incorrectly found that the defendant had withdrawn his motion and found the defendant fit. Dr. Chapman’s report had already been filed with the court. We must presume that the trial court had read the doctor’s report. Thus, it appears that the court made its decision on fitness based on the evidence in the record. However, confusion in the record about what was happening at the hearing renders the outcome too vague, considering the due process requirements raised in People v. Griffin, 178 Ill. 2d 65, 687 N.E.2d 820 (1997).

¶3Therefore, I agree with the majority that this court retain jurisdiction of the matter while allowing a limited remand for a retrospective fitness hearing.

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