People v. Hodge, 240 N.E.3d 77

Alvin A. Hodge was charged with two counts of aggravated robbery and remained in custody after bail was set at $1 million.
Hodge later filed a motion for pretrial release; the State responded with a petition to deny release, citing concerns about risk to community safety and that Hodge was on mandatory supervised release for a prior armed robbery.
The underlying incident involved two masked men robbing a pub with airsoft guns, leading to an exchange of gunfire in which an accomplice was killed and Hodge wounded.
The trial court granted the State’s petition to deny pretrial release, relying on specific statutory factors and using a check-the-box form for written findings.
On appeal, Hodge challenged (1) the sufficiency of the court’s written findings and (2) the timeliness of the State’s petition in response to his motion for pretrial release.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of written findings	Written findings on the court form met statutory standards	Court's check-the-box order did not satisfy statute	Order sufficient; statutory requirements were met
Timeliness of State’s detention petition	State could respond to defense motion for release	State's detention petition was untimely	State's response was timely and permissible

In re Madison H., 215 Ill. 2d 364 (purpose of written findings is to facilitate appellate review)
People v. Porter, 122 Ill. 2d 64 (written orders serve appellate review)
People v. Kurzeja, 2023 IL App (3d) 230434 (State may respond to defendant’s motion for release under bail reform)
People v. Rios, 2023 IL App (5th) 230724 (analogous procedures post-bail reform)