People v. Talbert, 2026 IL App (1st) 260489

Talbert was indicted for aggravated vehicular hijacking, armed robbery, stolen-vehicle and weapons offenses, and aggravated fleeing after a June 10, 2025 carjacking and police pursuit. 1
The State alleged Talbert armed himself with a Glock with a defaced serial number, forced victims from the car, and had ten prior violent juvenile adjudications. 2
At the June 11, 2025 detention hearing, the court found clear and convincing proof of the offense, dangerousness, and no conditions to protect the public, and ordered detention. 3
On December 10, 2025, a different judge again denied release after hearing arguments about delayed forensic testing and electronic monitoring. 4
After DNA testing excluded Talbert as a contributor to DNA on the recovered gun, he filed a March 5, 2026 motion for relief under Rule 604(h)(2). 5
The trial court denied that motion, and Talbert appealed, with the State arguing the motion was insufficient and the detention ruling was correct. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Talbert’s Rule 604(h) motion for relief sufficient? 7	Talbert’s motion identified the requested relief and grounds, satisfying the prerequisite.	The State said the motion was really a reconsideration motion and too late.	Yes; the motion sufficiently invoked Rule 604(h) and preserved the appeal. 8
Did the State prove Talbert likely committed the detention-eligible offense? 9	Talbert pointed to weak identification, missing forensic links, and exculpatory DNA.	The State relied on the proffer, victim identification, flight, and concealment.	Yes; the proof was evident or the presumption great. 10
Did Talbert pose a real and present threat to the community? 11	Talbert argued youth, family support, school, and lack of adult convictions.	The State cited repeated violent juvenile adjudications and the charged armed carjacking.	Yes; his violent history and the offense showed dangerousness. 12
Could any conditions mitigate the risk? 13	Talbert proposed curfew, home confinement, and electronic monitoring.	The State argued Talbert would not comply and monitoring was only reactive.	No; no condition would adequately protect the public. 14

People v. Morgan, 2025 IL 130626 (Ill. 2025) (de novo review applies when pretrial detention is decided on proffer alone; states the three detention questions 15)
Johansson v. Glink, 2021 IL App (1st) 210297 (Ill. App. Ct. 2021) (supreme court rule interpretation is reviewed de novo; motion character depends on content 16)
VC&M, Ltd. v. Andrews, 2013 IL 114445 (Ill. 2013) (statutory-style interpretation of supreme court rules focuses on plain language and intent 17)
People v. Patterson, 2025 IL App (1st) 250510 (Ill. App. Ct. 2025) (example where the filing did not satisfy the Rule 604(h) motion-for-relief prerequisite 18)
People v. Opas, 2025 IL App (1st) 250208 (Ill. App. Ct. 2025) (a motion for relief asks the trial court to reconsider pretrial detention 19)
People v. Reyes, 2026 IL App (1st) 252639 (Ill. App. Ct. 2026) (a motion for relief is the vehicle for reconsidering pretrial detention 20)
People v. Lanier, 2025 IL App (1st) 242603 (Ill. App. Ct. 2025) (a motion for relief functions as a reconsideration request in the pretrial-detention context 21)
People v. Hugo, 2024 IL App (1st) 241983-U (Ill. App. Ct. 2024) (treated a similar filing as a motion to reconsider detention 22)
Rowe v. Raoul, 2023 IL 129248 (Ill. 2023) (describes the statutory overhaul of Illinois pretrial release law 23)