Right to counsel claim waived by express consent; People v Carter; Ineffective assistance of counsel; Abandonment for lack of development; People v Henry

Holding that defendant expressly waived any right-to-counsel objection and abandoned his ineffective-assistance claim, the court affirmed his conviction. He was convicted of malicious destruction of property ($1,000 to $20,000) after scratching a vehicle in a grocery store parking lot. On appeal, the court rejected his argument that he was denied his right to counsel when an associate from appointed counsel’s firm represented him at trial because before jury selection, he agreed on the record to proceed with the associate and signed an order substituting him. “Waiver is ‘the intentional relinquishment or abandonment of a known right[,]’” and having expressly consented, he could not “‘harbor error at trial and then use that error as an appellate parachute.’” The court also rejected his ineffective-assistance claim because he supplied no developed argument or authority, and an “‘appellant may not merely announce his position and leave it to this Court to discover and rationalize the basis for his claims[.]’”