JUSTICE STEIGMANN delivered the opinion of the court:

This case requires us to determine whether criminal defense counsel may properly forcehis client to choose between testifying without his counsel's assistance or not testifying at all, whendefense counsel's determination that his client will commit perjury on the witness stand is based solely oncounsel's assessment of the evidence. We hold that he may not.

In February 1999, the State charged defendant, Cory W. Calhoun, with residentialburglary of Sarah Louderback's home. Evidence presented at defendant's May 1999 jury trial showedthat on February 22, 1999, defendant, who was driving Louderback's Chevy Blazer, dropped Louderbackoff at work and then drove her son, David, to his babysitter's house. Later that day, Louderback reportedto police that her Chevy Blazer and certain items from inside her home were missing. Later that night,defendant was arrested in Hannibal, Missouri, after Hannibal police spotted Louderback's Blazer, pulled itover, and found defendant at the wheel. Some of Louderback's missing items were found in the Blazer. Louderback testified at trial that she and defendant were friends but had never dated.

The jury convicted defendant of residential burglary (720 ILCS 5/19-3 (West 1998)), andthe trial court later sentenced him to 11 years in prison and ordered him to pay $420 in restitution and $331in court costs. The court also ordered the Department of Corrections (DOC) to withhold 50% ofdefendant's DOC wages and remit those funds to the circuit clerk to be applied toward the amounts duefor restitution and costs.

Defendant appealed, arguing that (1) the State failed to prove him guilty beyond areasonable doubt; (2) he was denied effective assistance of counsel at trial and in posttrial proceedings;and (3) the trial court lacked the authority to order the withholding of his DOC wages. This court agreedwith only defendant's third argument and thus affirmed his conviction and remanded with directions. People v. Calhoun, No. 4-99-0560 (November 13, 2000) (unpublished order under Supreme Court Rule23).

In October 2001, defendant pro se filed a petition for relief under the Post-ConvictionHearing Act (Act) (725 ILCS 5/122-1 through 122-8 (West 2000)), and the trial court later appointedpostconviction counsel for defendant.

In February 2002, postconviction counsel filed an amended postconviction petition,alleging that (1) defendant's trial counsel was ineffective in that he failed to (a) assist defendant intestifying in his own defense, (b) obtain phone records to impeach a State's witness, and (c) perfectdefendant's appeal of his sentence; (2) defendant was denied due process in that the amount he wasordered to pay in restitution was not supported by the evidence; and (3) defendant's 11-year sentenceconstituted cruel and unusual punishment. Later in February 2002, the State filed a motion to dismissdefendant's amended postconviction petition.

Following a February 2002 hearing, the trial court granted the State's motion to dismissdefendant's amended postconviction petition as to all of defendant's claims except his claim that his trialcounsel provided ineffective assistance when he refused to assist defendant in presenting his testimony. As to that claim, the trial court granted defendant an evidentiary hearing.

At the July 2002 evidentiary hearing, defendant testified that he and his trial counsel,Randall Prizy, first discussed whether defendant would testify after the trial court denied his motion for adirected verdict. In the trial court's chambers following that denial, Prizy informed the court that thedefense would not be putting on any evidence and he did not believe defendant would be testifying. Defendant interrupted and stated that he "had" to testify. The court then gave defendant and Prizy timeto discuss the matter outside chambers.

In the hallway outside the trial court's chambers, Prizy explained to defendant that itwould not be wise for him to testify because if he did so, all of his prior convictions would hurt him. Defendant and Prizy argued "vehemently." When they returned to the court's chambers, the courtexplained to defendant that his prior convictions could be a grave concern. The court asked theprosecutor what defendant's prior convictions were, and he informed the court of a few but did not have acomplete listing with him. Defendant said that he needed to testify, and he and Prizy again steppedoutside chambers. Prizy began by saying to defendant, "How is it going to look if you get up to testify andI got no questions to ask you?" Defendant was "stunned" and went back into the court's chambers andsaid that he was not going to testify. Defendant acknowledged that the court had earlier admonished himregarding his right to testify.

Defendant further testified that (1) he never told Prizy that he was guilty and had not toldPrizy what he would testify to if he took the stand; (2) he and Prizy did not discuss whether his testimonywould be truthful, only that his prior convictions would hurt him; and (3) he did not testify because Prizywould not help him do so. Defendant also testified that he did not tell the trial court that Prizy said hewould not help him testify and explained as follows: "Well I was stunned. I wish I would have now."

Prizy testified as follows regarding his first conversation with defendant following the trialcourt's denial of the motion for directed verdict.

"Generally it was one in which it was my advice to him not to take thestand generally because of his prior convictions. He had quite a fewfelony convictions we had dealt with. I didn't do a motion to see if wecould get any of those felonies thrown out because it was my intentionand my hope that [defendant] elected [sic] not to take the stand becauseI wasn't comfortable with his felony convictions and I also wasn't comfortable with his version of the events of that particular day where hewas charged with theft and the residential burglary. So I was leaningtowards advising him not to take the stand."

Prizy did not remember the conversation exactly but stated that they did discuss his discomfort withdefendant's version of events. Prizy acknowledged that he learned defendant's version of events monthsearlier--three or four days after he was appointed to represent defendant and prior to defendant'spreliminary hearing. Between the preliminary hearing and trial, Prizy and defendant discussed defendant's version of events "numerous times." Defendant's version was consistent each time they discussedit.

During their second conversation outside the trial court's chambers, Prizy and defendantcovered the same ground. Defendant told Prizy that (1) he wanted the jury to hear his story; (2)Louderback was lying; and (3) the jury would believe him. When asked whether a discussion occurredabout the way the trial would proceed if defendant testified, Prizy replied, as follows:

"When the situation comes to that, sometimes --I sometimes will tell adefendant, and I don't remember if I told [defendant] this, but I may havetold him that if by chance he testified, that it might be a narrative formbecause I still wasn't at all comfortable with his testimony. And I mayhave told him that he may have a better chance at telling the jury anything and everything that he wanted to, but it would be a narrative, itwouldn't be a question and answer period from me, it would be megetting up and asking him to give his own version, but we needed the[c]ourt's consent to do that. And if we did that and that was allowed, itwas my opinion to him that the jury would sense that something funnywas going on and they might not like it and they would more so scrutinizehis testimony."

Prizy did not recall whether he said this to defendant. At the end of their conversation, defendant decidednot to testify. Defendant never appeared to be shocked, upset, or alarmed by what Prizy told him. Prizyacknowledged that on the day of trial, he and defendant had some heated conversations and wereunhappy with each other. He further acknowledged that defendant was convinced of the truth of hisversion of events.

Prizy also testified that (1) he was convinced that defendant was going to commit perjury;and (2) he did not want defendant to get into any more legal trouble. When asked what it was aboutdefendant's version of events that caused Prizy to believe it would be perjurious, Prizy replied, as follows:

"A lot of very simple things to a lot of complicated things. [Defendant]maintained that he and [Louderback] were boyfriend, girlfriend.[Louderback] said that was not remotely true, that they were friends, nomore no less, but because of this that they were no longer friends.

She had a son by the name of [David]. [Defendant] had askedme to talk to him and subpoena him, I believe he was nine or ten yearsold at the time, that he would support [defendant's] story. That he wouldsay that they went back to the house and everything was fine and he wastaking care of him, that he didn't take anything in the house and therewas no problem, but--basically [defendant] told me that he was a normalgood kid who loved his mother and he and [defendant] were goodfriends. I met with [David] and his mother three or four days beforetrial, it was extremely obvious to me that he had large behavior problems. He could not sit still. He hit or kicked or slapped his mother five or sixtimes. *** And [defendant] told me that he was a normal, well-behavedchild and that just wasn't true.

[Louderback] insisted that she was--that [defendant] had took[sic] the car--that [defendant] took her car that morning. Theunderstanding between them was that he was supposed to take her towork and then he was supposed to take [David] to the baby[]sitter. Andaccording to [defendant,] they did that, and he was supposed to drop thecar off at the house, but he went to Hannibal, Missouri, and beyond. Andhe didn't have permission to take the car there and it just didn't match upat all with what [Louderback] said. And along with [Louderback], frommy point of view, she seemed to be telling the truth. I had to match thatup against [defendant's] version along with his multiple felonyconvictions, it seemed to me that he could be in a perjury situation.

There were a couple of other witnesses that he wanted me totalk to, which I did. Casey Wellman, the other name will come to me [in]a minute. I can't remember. I talked to both of those gentlemen, and[defendant] said they would support his version of everything. [Wellman] told me that he worked with [defendant] for two or threedays, months before, that was it. He didn't know [Louderback]. Hedidn't know anything about it. He didn't even know why I called him. And the other gentleman, I can't remember his name, he--I talked to himand he basically more or less said the same thing; that he didn't haveanything to do with [Louderback] or [defendant] and he didn't knowanything about this theft or burglary. *** And all the witnesses that[defendant] gave me I talked to and none of them helped him in hisdefense."

Prizy acknowledged that his sense that defendant would be committing perjury was based on the conflictbetween what defendant said and what the other witnesses said. Defendant never told Prizy that hisversion was a lie, nor does the record indicate that defendant deviated in what he wanted to tell the juryfrom what he had been telling Prizy.

Following the July 2002 hearing, the trial court entered a written order denyingdefendant's amended postconviction petition. Specifically, the court found that (1) Prizy had made agood-faith determination that defendant would commit perjury if he testified; and (2) thus, he did notprovide ineffective assistance of counsel.

This appeal followed.

Defendant argues that the trial court erred by denying his petition for postconviction reliefbecause he received ineffective assistance of counsel when Prizy refused to assist him in testifying. Specifically, he contends that Prizy did not have sufficient knowledge that he would commit perjury so asto justify withdrawing the assistance of counsel. We agree.

At the third stage of postconviction proceedings, we will not reverse the trial court'sdecision to deny a petitioner's claim after conducting an evidentiary hearing unless it is manifestlyerroneous. People v. Childress, 191 Ill. 2d 168, 174, 730 N.E.2d 32, 35 (2000). "A decision is manifestlyerroneous only if it contains error that is 'clearly evident, plain, and indisputable.' " People v. Frieberg, 305Ill. App. 3d 840, 847, 713 N.E.2d 210, 216 (1999), quoting People v. Ruiz, 177 Ill. 2d 368, 384-85, 686N.E.2d 574, 582 (1997).

To establish ineffective assistance of counsel, a defendant must satisfy the two-prongedtest set forth by the United States Supreme Court in Strickland v. Washington, 466 U.S. 668, 80 L. Ed. 2d674, 104 S. Ct. 2052 (1984). The Strickland test requires a defendant to show that (1) his counsel'sperformance was so seriously deficient as to fall below an objective standard of reasonableness under theprevailing professional norm; and (2) the deficient performance so prejudiced defendant as to deny him afair trial. People v. Nieves, 192 Ill. 2d 487, 494, 737 N.E.2d 150, 154 (2000). To successfully claimineffective assistance of counsel, a defendant "must overcome a strong presumption that the challengedactions of counsel were the product of sound trial strategy." People v. Metcalfe, 202 Ill. 2d 544, 561, 782N.E.2d 263, 274 (2002).

In Nix v. Whiteside, 475 U.S. 157, 89 L. Ed. 2d 123, 106 S. Ct. 988 (1986), the UnitedStates Supreme Court discussed how defense counsel should proceed upon learning that a client willcommit perjury upon taking the witness stand. In that case, the defendant, who was charged with themurder of Calvin Love, raised the theory that he stabbed Love in self-defense. Up until shortly before thedefendant's trial, the defendant consistently told his attorney that although he was convinced that Lovehad a gun in his hand at the time of the stabbing, he had not actually seen a gun. However, about a weekbefore trial, while preparing for his direct testimony, the defendant stated that he had seen somethingmetallic in Love's hand. When asked about this, the defendant responded, in essence, that he had to sayhe saw a gun in order to win his case. Defense counsel explained to the defendant that he could notassist him in testifying falsely and ultimately persuaded the defendant not to testify that he had seen a gun. Whiteside, 475 U.S. at 160-61, 89 L. Ed. 2d at 131, 106 S. Ct. at 991.

On collateral attack of his conviction for second-degree murder, the defendant arguedthat his rights to counsel and to testify in his own defense had been violated because, although he took thestand, his trial counsel had coerced him into not testifying that he had seen a gun. The Supreme Courtheld that neither of the defendant's rights was violated because the right to testify does not "extend totestifying falsely" (emphasis omitted) (Whiteside, 475 U.S. at 173, 89 L. Ed. 2d at 138, 106 S. Ct. at 997),and the right to counsel does not include the "right to have a lawyer who will cooperate with plannedperjury" (Whiteside, 475 U.S. at 173, 89 L. Ed. 2d at 139, 106 S. Ct. at 997). In so holding, the Courtwrote that an attorney's duty of confidentiality does not extend to a client's "announced plans to engage infuture criminal conduct." Whiteside, 475 U.S. at 174, 89 L. Ed. 2d at 139, 106 S. Ct. at 998. The Courtfurther wrote that "[w]hen an accused proposes to resort to perjury or to produce false evidence, oneconsequence is the risk of withdrawal of counsel." Whiteside, 475 U.S. at 174, 89 L. Ed. 2d at 139, 106S. Ct. at 998. Accordingly, "[f]or defense counsel to take steps to persuade a criminal defendant totestify truthfully, or to withdraw, deprives the defendant of neither his right to counsel nor the right totestify truthfully." Whiteside, 475 U.S. at 173-74, 89 L. Ed. 2d at 139, 106 S. Ct. at 997-98.

Although Whiteside established that a defendant's constitutional rights are not violatedwhen his trial counsel takes steps to avoid assisting him in committing perjury, it did not address theprecise issue now before us. In Whiteside, the defendant told his attorney he intended to testify about anexculpatory matter that he had never previously mentioned. The Court's opinion addressed theappropriate action for an attorney to take under those circumstances. Whiteside thus did not addresswhat, if anything, short of a defendant's announced intention to commit perjury, constitutes a sufficientbasis upon which defense counsel can conclude that his client intends to commit perjury and take thosesteps the Court deemed appropriate. This is essentially the question now before us--that is, was theinformation known to Prizy sufficient to show that defendant's testimony would be perjurious so as tojustify Prizy's act of persuading defendant not to testify by threatening to withdraw his assistance? Although the United States Supreme Court has not addressed this question, Illinois and other state andfederal courts have.

The Supreme Court of Illinois interpreted Whiteside in People v. Flores, 128 Ill. 2d 66,538 N.E.2d 481 (1989). In that case, the defendant claimed in his postconviction petition and argued onappeal that he had received ineffective assistance of trial counsel when his counsel (1) refused to permithim to testify to a particular alibi and (2) failed to interview or call several witnesses (members of thedefendant's family) who would have testified to the same alibi. Flores, 128 Ill. 2d at 103, 538 N.E.2d at496. At an evidentiary hearing on the defendant's postconviction petition, defense counsel testified that hehad decided not to call the alibi witnesses because their proposed testimony would not have been helpfulin light of conflicting admissions the defendant had made. Flores, 128 Ill. 2d at 104-05, 538 N.E.2d at 497. Defense counsel also testified that (1) the defendant's purported alibi conflicted with statements thedefendant had made to the police and (2) the defendant had previously provided defense counsel withthree different explanations for his whereabouts at the time of the crime. Flores, 128 Ill. 2d at 105-06, 538N.E.2d at 497. The Flores court then wrote the following:

"Confronted with the contradictions between what the members of thedefendant's family would testify to and what defendant himself had toldcounsel, [defense counsel] could reasonably have concluded that thepresentation of this testimony would have been improper on his part. ***

The defendant argues, however, that unless defense counsel hadactual knowledge that the testimony was perjurious, his mere suspicion isinsufficient grounds to refuse to call an alibi witness. We disagree, asdefense counsel should have discretion to make a good-faithdetermination whether particular proposed witnesses for the defendantwould testify untruthfully. Absent some showing that counsel's decisionwas unreasonable under the circumstances, we cannot say that thedefendant was denied a fair trial as a consequence of counsel's electionnot to call the members of his family to present an alibi. For the samereason, defense counsel was not incompetent in refusing to permit thedefendant to testify to the purported alibi." Flores, 128 Ill. 2d at 107, 538N.E.2d at 498.

In People v. Bartee, 208 Ill. App. 3d 105, 106, 566 N.E.2d 855, 856 (1991), the SecondDistrict Appellate Court considered whether the defendant received ineffective assistance of counsel andwas denied a fair trial when the trial court ordered him to testify in the narrative after his defense counselinformed the court that he had to withdraw from the case due to a Whiteside "problem." Citing Flores, theSecond District held that defense attorneys are afforded "great discretion" in determining whether aclient's testimony will constitute perjury. Bartee, 208 Ill. App. 3d at 108, 566 N.E.2d at 857. Accordingly,the Second District rejected the defendant's argument that he was entitled to a hearing at which hisdefense counsel would have to show a firm factual basis for his belief that the defendant would testifyfalsely. Bartee, 208 Ill. App. 3d at 108, 566 N.E.2d at 857. The court thus concluded that the defendanthad not been denied a fair trial or effective assistance of counsel when he was ordered to testify in thenarrative. Bartee, 208 Ill. App. 3d at 108, 566 N.E.2d at 857.

The Second District addressed the issue again in People v. Taggart, 233 Ill. App. 3d 530,599 N.E.2d 501 (1992). In that case, prior to presenting the defense, defense counsel went on the recordto explain in great detail his investigation of the defendant's purported alibi. Defense counsel concludedthat he could not present any alibi witnesses. Taggart, 233 Ill. App. 3d at 559, 599 N.E.2d at 521. Later,when the defendant indicated that he would testify, defense counsel stated that based on his conversationswith the defendant and ethical considerations, he would only ask the defendant his name and to tell hisversion of events. Taggart, 233 Ill. App. 3d at 559, 599 N.E.2d at 522.

On appeal, the defendant claimed that he had been deprived of his sixth amendment rightto counsel. In rejecting the defendant's claim, the Second District concluded that defense counsel'sreference to "ethical considerations" and explanation for his belief that no basis existed for an alibidefense evinced his good-faith determination that the defendant was going to commit perjury. Taggart,233 Ill. App. 3d at 560, 599 N.E.2d at 522. Thus, the court further concluded that the Flores standardwas satisfied. Taggart, 233 Ill. App. 3d at 560, 599 N.E.2d at 522. The Second District also noted,however, that "[i]n these types of cases, it is important to identify on the record the basis for counsel'sbelief [that his client will commit perjury] so a proper determination of its reasonableness can be made." Taggart, 233 Ill. App. 3d at 560, 599 N.E.2d at 522.

In light of Flores, Bartee, and Taggart, we conclude that the trial court in this case appliedthe correct standard in considering defendant's postconviction claim--namely, whether Prizy's decision tooffer defendant the choice of testifying in the narrative or not at all was based on a good-faithdetermination that defendant was going to commit perjury. We disagree, however, with the trial court'sdecision because we conclude that Prizy's determination that defendant was going to commit perjury wasnot reasonable under these circumstances. See Flores, 128 Ill. 2d at 107, 538 N.E.2d at 498 ("[a]bsentsome showing that counsel's decision was unreasonable under the circumstances," counsel should havediscretion to make a good-faith determination whether a proposed witness will testify untruthfully).

Nothing in the record shows that defendant would have committed perjury had hetestified. Throughout defendant's discussion of this case with Prizy, defendant's version of events did notwaver. Prizy acknowledged that defendant (1) never told him that he was going to lie and (2) neverchanged his story. Prizy also testified that defendant believed his version of events to be truthful. According to Prizy's own testimony, his determination that defendant would commit perjury was based on(1) his belief that Louderback was more credible than defendant; (2) the discrepancy between (a)defendant's description of David and (b) Prizy's assessment that David would be a poor witness; and (3)Prizy's assessment that two other suggested witnesses would not have been helpful to defendant's case. In sum, Prizy was not "comfortable" with defendant's story.

Although our supreme court has held that defense counsel has "broad discretion" indetermining when a client will commit perjury, such discretion is not unlimited. A good-faith determinationthat a client will commit perjury cannot be based merely on defense counsel's assessment of the evidence. The simple fact that the testimony of other witnesses will contradict the defendant's version of eventscannot serve as the basis for defense counsel's conclusion that his client will commit perjury. To concludeotherwise would effectively be to give defense counsel unlimited discretion to reach such a conclusion,given that such testimonial conflicts arise in most, if not all, criminal cases. Such conflicts are for the juryto resolve. Moreover, defense counsel's responsibility to zealously represent his client does not dissipatesimply because counsel does not believe his client's story or the weight of the evidence lies in the State'sfavor. We thus hold that defense counsel's good-faith determination that his client will commit perjurymust rest on some articulable basis, apart from counsel's assessment of the evidence.

In so holding, we note that the circumstances of this case fall far short of those at issue inWhiteside. In that case, the defendant announced to defense counsel his intent to testify about anexculpatory matter that he had never previously mentioned. Whiteside, 457 U.S. at 160-61, 89 L. Ed. 2dat 131, 106 S. Ct. at 991. The facts of this case are also not analogous to the facts in Flores, in which thedefendant had provided defense counsel with several conflicting stories. Flores, 128 Ill. 2d at 105-06, 538N.E.2d at 497.

Instead, the facts of this case are similar to those in United States v. Midgett, 342 F.3d321 (4th Cir. 2003). In that case, the defendant never indicated to his defense counsel that he wouldtestify falsely and never changed his story. Midgett, 342 F.3d at 326. The Fourth Circuit Court ofAppeals considered whether the information known to defense counsel was sufficient to show that thedefendant's testimony would be perjurious. In concluding that the trial court had impermissibly forced thedefendant to choose between his right to testify and his right to counsel, the Fourth Circuit drew adistinction between "known perjury," which the trial court has an obligation to keep from the jury, andtestimony that the court merely believes is outweighed by other evidence. Midgett, 342 F.3d at 327. In soconcluding, the court analyzed the facts of the case, as follows:

"[The defendant] had apparently been consistent in his interviews withhis lawyer that a third person committed the [c]ount [o]ne crime and thathe did not. Defense counsel's responsibility to his client was notdependent on whether he personally believed [the defendant], nor did itdepend on the amount of proof supporting or contradicting [thedefendant's] anticipated testimony regarding how the incident happened. In this situation, [the defendant] never indicated to his attorney that histestimony would be perjurious. Thus, his lawyer had a duty to assist[him] in putting his testimony before the jury, which would necessarilyinclude his help in [the defendant's] direct examination. [Whiteside,] 475U.S. at 189, [89 L. Ed.2d at 149,] 106 S. Ct. [at 1005] (Blackmun, J.,concurring) ('Except in the rarest of cases, attorneys who adopt the roleof the judge or jury to determine the facts pose a danger of deprivingtheir clients of the zealous and loyal advocacy required by the [s]ixth[a]mendment'. (internal quotation marks, citations, and punctuationomitted)).

Defense counsel's mere belief, albeit a strong one supported byother evidence, was not a sufficient basis to refuse [the defendant's]need for assistance in presenting his own testimony." Midgett, 342 F.3dat 326.

We find the Midgett court's analysis persuasive and thus conclude that the trial court'sfindings that (1) Prizy made a good-faith determination that defendant would commit perjury and (2)defendant thus did not receive ineffective assistance of counsel were manifestly erroneous. Accordingly,we reverse the court's denial of defendant's postconviction claim and remand with directions to grantdefendant a new trial. In light of our decision, we need not address the other arguments defendant raises.

Despite our conclusion that Prizy's conduct in this case did not satisfy Illinois' good-faith-determination standard, we nevertheless invite our supreme court to reconsider the appropriateness of thatstandard. Although the Flores court clearly set that standard when it held that "defense counsel shouldhave discretion to make a good-faith determination" as to whether a defendant will commit perjury, thecourt's analysis was enmeshed with its analysis of defense counsel's strategic decision not to call certainwitnesses. Flores, 128 Ill. 2d at 107, 538 N.E.2d at 498. Yet, that strategic decision is entirely defensecounsel's to make (see People v. Ramey, 152 Ill. 2d 41, 54, 604 N.E.2d 275, 281 (1992)) and creates nosixth amendment issues. This, of course, is in stark contrast to issues concerning the defendant's owntestimony, but the Flores court did not acknowledge the constitutional and ethical ramifications that arisewhen the defendant's testimony is at issue. See Midgett, 342 F.3d at 326 (citing a defendant's sixthamendment right to assistance of counsel and constitutional right to testify on his own behalf as implicatedwhen client-perjury issues arise). Nor did the Flores court address the significant risk of unfair prejudicethat results when defense counsel reveals that he believes his client will testify falsely. See United Statesv. Long, 857 F.2d 436, 447 (8th Cir. 1988) (noting that once defense counsel makes a motion to withdrawor allows his client to testify in the narrative, "the die is cast. The prejudice will have occurred. At aminimum, the trial court will know of the defendant's potential perjury"). In addition, Flores provides noguidance to trial courts and attorneys as to (1) whether or when defense counsel should bring concernsabout client perjury to the trial court's attention, (2) whether or when the prosecutor should becomeinvolved, (3) whether the defendant has a right to be present when defense counsel notifies the court thathe believes the defendant will commit perjury, or (4) the making of a record on these matters.

Further, we note that no other jurisdiction has adopted Illinois' good-faith-determinationstandard. Instead, our research has revealed that standards adopted by other jurisdictions include thefollowing: (1) actual knowledge, meaning that the defendant has made an "unambiguous" statementdirectly to the attorney regarding the intent to commit perjury (State v. McDowell, 2004 WI 70