People v. Robles, 2024 IL App (4th) 231168

Alexander Robles was charged with aggravated battery and domestic battery, with allegations of physically assaulting Hannah S. Kirkpatrick.
Robles had three previous convictions for domestic battery and was already on bond for another domestic battery case with a different, pregnant victim.
The State petitioned for Robles’ pretrial detention, arguing he posed a threat to public safety and was a flight risk, citing past failures to appear in court.
At the hearing, defense counsel countered there had been no further contact with the alleged victim and offered potential mitigating measures such as electronic monitoring and participation in pretrial services.
The trial court denied pretrial release, finding Robles posed a real and present threat and no combination of conditions could sufficiently protect the community or victims.
Robles appealed, arguing the State failed to meet the necessary burden to deny pretrial release under Illinois’ Pretrial Fairness Act.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Denial of pretrial release due to danger	Robles’ history & current charges showed ongoing risk	No new incidents; willing to accept supervision or monitoring	Court found Robles posed ongoing threat, affirmed denial
Denial of pretrial release for willful flight	Robles had history of failures to appear	Failures to appear don’t equal willful flight under law	Court found insufficient proof of willful flight
Whether conditions could mitigate threat	No conditions would ensure community/victim safety	Ankle monitor, pretrial services, no contact with victim as safeguards	Court found no suitable conditions could mitigate threat
Compliance with Pretrial Fairness Act	Statutory burden met for pretrial detention	State failed to show clear and convincing evidence threat couldn’t be mitigated	Court found clear and convincing evidence supported detention