People v. Grandberry
230 N.E.3d 272
Ill. App. Ct.2024Background
- Raven Chanel Grandberry was indicted for two counts of aggravated battery of a peace officer and six counts of aggravated battery of a nurse stemming from an incident on April 2, 2023.
- The State alleged that Grandberry spat on officers and nurses and bit a nurse's finger, resulting in bruising, but did not claim any victim suffered great bodily harm, permanent disability, or disfigurement.
- Grandberry's pretrial bond was set at $100,000, and she remained in custody due to inability to pay.
- The State filed a petition to deny pretrial release, arguing the charges qualified as detainable offenses under the pretrial detention statute.
- The circuit court granted the State's petition, finding the offenses detainable, and Grandberry appealed that decision.
Issues
| Issue | State's Argument | Grandberry's Argument | Held |
|---|---|---|---|
| Whether aggravated battery of a peace officer/nurse (without great bodily harm) is a detainable offense under §110-6.1(a)(1.5) | Charges involve the threat of great bodily harm, fulfilling the "any other felony" clause for pretrial detention | Aggravated battery is only a detainable/forcible felony if great bodily harm, permanent disability, or disfigurement results, per statute's limiting language | Court ruled such charges (without great bodily harm) are not detainable offenses under the statute |
Key Cases Cited
- People v. Trottier, 2023 IL App (2d) 230317 (standard of review for trial court's denial of pretrial release, considering abuse of discretion)
- People v. Horne, 2023 IL App (2d) 230382 (clarified standards for abuse of discretion and manifest weight of the evidence in pretrial release decisions)
- People v. Taylor, 2023 IL 128316 (statutory construction is a de novo review question)