2024 IL App (2d) 230546
Ill. App. Ct.
2024
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Background

  • Teion D. Jones was charged in Kane County, Illinois, with escape/violating electronic home monitoring (EHM) and criminal damage to government property.
  • At the time of the incident, Jones was on EHM for another felony, on pretrial release in three other cases, on probation in two cases, and previously adjudicated delinquent in five juvenile cases.
  • The State filed a petition to deny pretrial release citing a high likelihood of willful flight and the inadequacy of any conditions other than detention to prevent flight.
  • Evidence included police reports stating Jones tampered with and removed his EHM device, avoided police contact, and fled from law enforcement, culminating in his apprehension in an abandoned residence.
  • The trial court granted the State's petition, finding clear and convincing evidence of risk of flight, and ruled no lesser conditions would be adequate; Jones appealed the pretrial detention order.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether police synopses alone suffice as clear and convincing evidence for detention. Synopses supported by reliable information meet the Act’s standard. Synopses alone are insufficient. Police synopses may meet the burden if reliable.
Whether the State proved no condition or combination mitigates risk of flight. Defendant’s conduct showed willful flight history, lesser conditions previously failed. Synopses and some exhibits did not prove risk; defendant resided at reported address. Evidence sufficed to prove no lesser condition would suffice.
Whether the court wrongly applied a standard about ensuring later appearances or preventing future offenses. State contended this standard was inapplicable here. No evidence of prior failures to appear or new charges shown. The cited standard applies to revoked/mod. pretrial releases, not defendant's circumstances.

Key Cases Cited

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