People v. Hall, 2017 IL App (3d) 160541

Charles J. Hall (then 19) committed aggravated criminal sexual abuse involving a 10‑year‑old; State filed a Sexually Dangerous Persons Act petition in 2006, and Hall admitted the petition’s allegations; court committed him to the DOC for treatment.
Hall had earlier juvenile and adult sexual offenses, admissions of masturbation to child images, conviction for cruelty to animals (killing a cat and masturbating on it), and an October 2005 statement about intending to snatch a child on Halloween.
Treatment records showed poor engagement: numerous tickets (many for missing or leaving groups), repeated suspensions/probations in the program, and ratings of “unsatisfactory” or “considerable need for improvement” on semiannual reviews.
State’s expert (Dr. Clounch) diagnosed three paraphilic disorders (sexual sadism, zoophilia, pedophilic disorder), used Static‑99R and Stable‑2007 (both high risk), identified dynamic risk factors, and opined Hall remained substantially likely to reoffend without confinement.
Defense expert (Dr. Witherspoon) disputed paraphilia diagnoses and actuarial tools’ applicability to juvenile‑onset offenders, recommending release with general mental‑health supervision; the court credited the State’s expert.
The trial court found by clear and convincing evidence Hall remained sexually dangerous and denied discharge/conditional release; the appellate court affirmed (standard: manifest‑weight review).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hall remained a "sexually dangerous person" under the Act (risk to reoffend)	State: Expert diagnoses, actuarial scores, dynamic risk factors, treatment nonprogress show substantial probability of reoffense.	Hall: Expert says no paraphilias; actuarials overpredict for juvenile‑onset offenders; treatment evaluation biased; lack of progress due to program rules.	Court: Affirmed — substantial evidence (paraphilia diagnoses, actuarials, dynamic factors, poor treatment progress) supports finding of continued sexual dangerousness.
Proper standard of appellate review for a recovery hearing	State: Implicitly argued a more deferential, Collins‑style standard; cited initial‑commitment cases.	Hall: Appellate review should be manifest‑weight (whether opposite conclusion is clearly apparent).	Court: Adopted manifest‑weight standard for recovery hearings and held trial court’s finding was not against manifest weight of evidence.

People v. Collins, 106 Ill. 2d 237 (1985) (discusses reasonable‑doubt review standard principles)
People v. Trainor, 196 Ill. 2d 318 (2001) (prior law on burden in recovery proceedings)
People v. Masterson, 207 Ill. 2d 305 (2003) (explains "substantially probable" requirement for sexual‑dangerous findings)
In re Commitment of Sandry, 367 Ill. App. 3d 949 (2006) (appellate standard: manifest‑weight review in commitment context)
People v. Bingham, 2014 IL 115964 (2014) (addresses burden in initial sexually dangerous/violent person proceedings)
People v. Craig, 403 Ill. App. 3d 762 (2010) (discusses statutory burden of proof at recovery hearings)