People v. Hovenec

Defendant was charged with armed robbery. Following a bench trial, the court convicted him of robbery and sentenced him to three years’ imprisonment. On appeal, defendant contends that: (1) since the trial judge concluded that no force was used until after the taking, his robbery conviction must be reversed; (2) the trial judge erred in failing to appoint new counsel to investigate his claim of ineffective assistance of counsel; and (3) he did not make a knowing and intelligent waiver of his right to counsel at his post-trial hearing.

Complainant Shukri Judeh testified that he owned a liquor…