People v. Inman
2023 IL App (4th) 230864
Ill. App. Ct.2023Background
- William R. Inman was charged across three Warren County cases with multiple felonies including two methamphetamine deliveries, meth possession, several firearm-possession counts, and armed violence.
- The State filed a verified petition under 725 ILCS 5/110-6.1 seeking pretrial detention, alleging Inman posed a "real and present threat."
- Evidence and proffer: two controlled buys to a confidential source, surveillance during buys, and a search warrant at Inman’s residence that recovered a loaded 9mm handgun, a .22 rifle, magazines/ammunition, digital scales, drug packaging, and methamphetamine.
- Pretrial services rated Inman as a "moderate high" risk to fail to appear and to reoffend; he has prior convictions (Iowa and Illinois) including assaultive- and drug-related offenses.
- The circuit court denied pretrial release, making written findings that the offenses were detainable, Inman posed a real and present threat, and no condition or combination of conditions could mitigate that threat.
- On appeal under Illinois Supreme Court Rule 604(h), Inman filed a bare checkbox claim (no record citations or argument). The appellate court affirmed the denial and remanded for further proceedings.
Issues
| Issue | State's Argument | Inman's Argument | Held |
|---|---|---|---|
| Whether the State proved by clear and convincing evidence that no condition or combination of conditions could mitigate the real and present threat or prevent flight under 725 ILCS 5/110-6.1 | The record (controlled buys, weapons and drug paraphernalia recovered, criminal history, risk score) supports detention | The State failed to meet its clear-and-convincing burden that no less-restrictive conditions could mitigate the threat or prevent flight | Affirmed — court found clear and convincing evidence and specific articulable facts to detain; no abuse of discretion |
| Proper standard of appellate review for a Rule 604(h) pretrial-detention appeal | Review remains abuse of discretion; appellate court should not reweigh evidence | (Implicit) Rule 604(h) claimant requests relief; no different standard argued | Held — abuse-of-discretion standard applies; appellate court will not substitute its judgment for the trial court on credibility/weight of evidence |
| Sufficiency of appellant’s Rule 604(h) notice when it lacks factual and legal argument | The written record and trial court findings show compliance with statutory requirements; the State urged affirmance | Inman submitted only a checked box asserting the statutory claim without citing record or authority | Held — bare checkbox is inadequate to develop arguments; appellate court will not invent arguments for appellant but reviewed record and found no reversible error |
| Whether the circuit court complied with statutory findings required by §110-6.1 (detainable offense; real and present threat; no feasible conditions) | The court made required written findings, citing multiple firearms, recent deliveries, showing a firearm to a confidential source, criminal history, and risk assessment | (Implicit) Inman challenged sufficiency of proof that no conditions would mitigate the threat | Held — court satisfied §110-6.1: found detainable offenses, real and present threat, and that no conditions would mitigate the threat; findings supported by specific articulable facts |
Key Cases Cited
- Rowe v. Raoul, 2023 IL 129248 (discusses pretrial-release changes under the Pretrial Fairness Act)
- People v. Becker, 239 Ill. 2d 215 (abuse-of-discretion standard and limits on appellate substitution of judgment)
- People v. Cox, 82 Ill. 2d 268 (appellate review: courts should not reweigh evidence or substitute judgment)
- U.S. Bank v. Lindsey, 397 Ill. App. 3d 437 (appellate court is not the advocate for an appellant; courts should not craft arguments for parties)
- Obert v. Saville, 253 Ill. App. 3d 677 (same principle: appellate courts will not assume the role of appellant’s advocate)