Is Stipulated Bench Trial Considered a Guilty Plea ?

People v. Horton, 143 Ill. 2d 11,22, 570 N.E.2d 320, 155 Ill. Dec. 807 (1991), provided the seminal law regarding when a stipulated bench trial is tantamount to a guilty plea and when Rule 402(a) admonishments are required. Horton involved two stipulated bench trials. Based on the facts of the first stipulated bench trial, the supreme court adopted the rule that a stipulated bench trial is not tantamount to a guilty plea if the defendant presented and preserved a defense. Horton, 143 Ill. 2d at 22. With respect to the facts of the second stipulated bench trial, the supreme court held that, even though the defendant presented and preserved a defense, if the defendant stipulated to the sufficiency of the evidence to convict, the defendant must be afforded the protections set forth by Rule 402(a). Horton, 143 Ill. 2d at 22. However, the law regarding when a stipulated bench trial is tantamount to a guilty plea has been further clarified by the supreme court in People v. Campbell, 208 Ill. 2d 203, 802 N.E.2d 1205, 280 Ill. Dec. 684 (2003).