Lawyer's Failure to Tender Illinois Pattern Jury Instructions Criminal No. 3.17

In People v. Lewis, 240 Ill. App. 3d 463, 609 N.E.2d 673, 182 Ill. Dec. 139 (1992), the appellate court found that defense counsel erred by failing to tender Illinois Pattern Jury Instructions, Criminal, No. 3.17 (2d ed. 1981). The court, however, found that this error alone did not require reversal since the jury was instructed that in determining the credibility of witnesses, it should consider any interest, bias or prejudice the witness might have. Lewis, 240 Ill. App. 3d at 467-68.