2024 IL App (1st) 240299
Ill. App. Ct.2024Background
- Marquise Ramyyeh was charged with armed robbery with a firearm and detained pretrial based on alleged dangerousness.
- At the detention hearing, defense received summaries—not videos—of complaining witnesses’ statements and some police reports.
- The State argued it only had summaries available and was not obligated to provide more than what was in its possession at the time.
- Defense argued section 110-6.1(f)(1) of the Illinois Code required disclosure of all video statements and police reports in the State’s possession, even those related to prior convictions.
- The circuit court ruled the State complied by providing what it had, noting defense could access prior reports via public records or other means.
- On appeal, Ramyyeh contended he was denied a fair hearing and sought reversal of his detention based on inadequate disclosure.
Issues
| Issue | Ramyyeh's Argument | State's Argument | Held |
|---|---|---|---|
| Whether State must provide video statements if not in its possession | State must provide all relied-upon video statements | Only need to tender what is actually in its possession | State need only provide what is possesses |
| Whether State must provide all police reports in its possession | All police reports in prosecutor’s possession (used at hearing) | Defense access through other means suffices | Prosecutor must provide police reports possessed |
| Remedy for noncompliance with statutory disclosure requirement | Vacate the detention order, remand, and bar another petition | Reversal/remand unnecessary for just missing report | Reverse and remand for a new detention hearing |
Key Cases Cited
- People v. Perry, 224 Ill. 2d 312 (Ill. 2007) (plain language of statute governs and must be applied as written)
- People v. Maya, 105 Ill. 2d 281 (Ill. 1985) (related statutes should be construed harmoniously)