People v. Morgan, 2025 IL 130626

Kendall Cecil Morgan was charged with home invasion and domestic battery after an altercation with Vanessa Williams, where he allegedly forced entry and caused her bodily harm in the presence of minor children.
The State petitioned to deny Morgan pretrial release, arguing he was a real and present threat and no conditions could mitigate this danger; the hearing was held by proffer, not live testimony.
The trial court found that the State's burden was met and denied pretrial release, citing Morgan’s criminal history, recent violence, and assessed risk.
On appeal, Morgan argued that the State failed to show by clear and convincing evidence that no conditions of release could mitigate the risk, and that the appellate court should review the trial judge's decision de novo.
The appellate court instead reviewed the trial court’s decision under an abuse of discretion standard and affirmed the detention; the Supreme Court granted review to resolve the correct standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Appropriate standard of appellate review for pretrial detention decisions under §110-6.1, specifically when decision is based solely on proffered evidence	Abuse of discretion or manifest weight; defer to trial judge	De novo review when based only on proffer (no live testimony); mixed standard if live testimony	De novo review when no live testimony at detention hearing, manifest weight when live testimony; abuse of discretion is inappropriate
Applicability of manifest weight standard for factual findings based on proffered evidence	Applies regardless of evidence form	Not warranted without live testimony	Manifest weight standard only applies when trial judge hears live testimony
Whether abuse of discretion standard is proper for factual detention findings	Affords trial court necessary deference	Standard is too deferential, not appropriate for fact findings without live testimony	Abuse of discretion standard is not appropriate for findings based solely on proffered evidence
Whether pretrial detention decision is a factual, discretionary, or legal question	Discretionary (judgment call by trial court)	Binary factual determination under statutory criteria	Factual determination, not discretionary; ultimate decision is based on fact-finding and statutes

Best v. Best, 223 Ill. 2d 342 (Ill. 2006) (manifest weight of the evidence standard for live testimony-driven factual findings)
Addison Insurance Co. v. Fay, 232 Ill. 2d 446 (Ill. 2009) (de novo review where evidence was only documentary/deposition)
In re C.N., 196 Ill. 2d 181 (Ill. 2001) (standard of review for parental unfitness findings)
Cleeton v. SIU Healthcare, Inc., 2023 IL 128651 (Ill. 2023) (de novo review is proper when only proffered/documentary evidence)
People v. Mikolaitis, 2024 IL 130693 (Ill. 2024) (state may use proffer to meet burden for pretrial detention)
In re D.T., 212 Ill. 2d 347 (Ill. 2004) (factfinding with statutory factors is not a discretionary act)