The Third District affirmed in part and reversed in part, holding that the court failed to conduct an adequate inquiry on only two issues: trial counsel's failure to present mitigating evidence at sentencing and trial counsel's possible conflict of interest. People v. Barner, 2022 IL App (3d) 200433-U, ¶ 42 (Barner II). It explained that "[o]n those two claims-and only on those two claims-we hold that the circuit court erred.

Whether counsel's decision to introduce a particular witness or piece of evidence at trial was the result of sound trial strategy will often depend on facts not in the record. See, e.g., People v. Barner, 2022 IL App (3d) 200433-U, ¶ 39 (finding a preliminary Krankel inquiry inadequate where the record did not indicate why counsel failed to present any mitigating evidence at sentencing); see also People v. Brown, 2022 IL App (1st) 191628-U, ¶ 70 (finding an inquiry inadequate where it was not possible to discern from the record whether trial counsel was aware of certain testimony).