People v. SingletonPeople v. Singleton
ORDER
¶ 1 Held: The appellate court affirmed, finding the circuit court did not abuse its discretion in granting defendant pretrial release.
¶ 2 The State appeals the circuit court‘s order granting defendant, James Singleton, pretrial release pursuant to article 110 of the
¶ 3 On appeal, the State argues this court should overturn the circuit court‘s decision because the court erred when it determined (1)
I. BACKGROUND
¶ 4 ¶ 5 In February 2023, defendant pleaded guilty to one count of unlawful failure to register as a violent offender against youth (
¶ 6 Eight days later, defendant filed a motion to reconsider his pretrial release conditions. In support of his motion, defendant argued his most recent battery offense was not a detainable offense under
¶ 7 On October 16, 2023, the matter proceeded to a hearing on defendant‘s motion to reconsider. In support of his motion, defendant testified on his own behalf. According to
¶ 8 Following defendant‘s testimony, defense counsel proffered the pretrial interview with defendant‘s mother, Barbara Singleton, who indicated she and defendant were leaving her residence for the hospital when Richardson “showed up *** unannounced.” When asked to leave, Richardson refused, and “at some point [Richardson] had some sort of an object in her hand.” Barbara “thought it could have possibly been a hammer.” Although Barbara “wasn‘t sure who had initiated physical contact first, *** she did say that if [Richardson] had just left *** when she was asked to leave ***, none of this would have ever happened.”
¶ 9 In response, the State proffered photographs taken of Richardson on the day of the battery and described the factual basis supporting its petition to revoke, which indicated the following, in relevant part:
“[O]n or about September 23rd of 2023, at approximately 10:12 a.m., officers responded to 3311 Sun Valley Terrace, Apartment 10 in response to a battery.
The victim stated that the defendant battered her and made her hand bleed. On arrival, the defendant was not located inside the
residence. The victim said that the defendant was her daughter‘s uncle. The victim stated she arrived to check on the defendant‘s mother, who had recently had a stroke. When the victim asked the defendant‘s mother if she had eaten, the defendant said he, quote, unquote got this. The defendant used a closed fist to punch the right side of the victim‘s face three times, which stunned her. The defendant continued to punch the victim an unknown number of times which forced her against a wall. The defendant used his foot to kick her stomach three times and pulled her to the ground by her hair. The victim attempted to walk towards the door, but defendant continued to punch and kick her body, which caused her to fall to the ground, and at that time, the defendant kicked the victim‘s body and jaw area six times until a neighbor arrived to separate them.
Officers observed several cuts or scrapes to her body, three knots to the victim‘s forehead and one to her bottom lip. She did refuse medical treatment from Rockford Fire.”
¶ 10 Ultimately, the circuit court granted defendant pretrial release pending the hearing on the State‘s petition to revoke his conditional discharge. Under
¶ 11 Despite defendant‘s prior history of violence, the circuit court determined defendant was “unlikely to pose a danger to any other person or to the community at large.” The court also expressed doubt as to whether the State could prove its case and stated defendant‘s alleged battery of Richardson was unlike “random acts of violence such as bar fights and other different things.” Rather, the altercation was “a family issue” that occurred when Richardson “came into the house uninvited *** at a point in time where [defendant] was already there.” Defendant was also aware he was to have no contact with the victim, and the court believed defendant‘s “motivation of being able to care for his ailing mother would make it unlikely that [he] would pose a direct danger to Ms. Richardson.”
¶ 12 The circuit court then ordered defendant released with the conditions he (1) not violate any law, (2) report to the Winnebago County court services, (3) submit himself to the orders and process of the court, (4) notify the Winnebago County circuit clerk of any change of address, and (5) have no contact with Richardson. After the court entered its written order detailing the conditions of defendant‘s pretrial release, the State filed its notice of appeal under Illinois Supreme Court Rule 604(h)(1)(i) (eff. Oct. 19, 2023).
¶ 13 This appeal followed.
¶ 14 II. ANALYSIS
¶ 16 The determination of whether pretrial release should be granted or denied is reviewed under an abuse-of-discretion standard. See People v. Jones, 2023 IL App (4th) 230837, ¶¶ 27, 30. “An abuse of discretion occurs when the circuit court‘s decision is arbitrary, fanciful or unreasonable or where no reasonable person would agree with the position adopted by the [circuit] court.” (Internal quotation marks omitted.) People v. Simmons, 2019 IL App (1st) 191253, ¶ 9, 143 N.E.3d 833. Under this standard, a reviewing court will not substitute its own judgment for that of the circuit court simply because it would have analyzed the proper factors differently. People v. Inman, 2023 IL App (4th) 230864, ¶ 11.
¶ 17 The Code creates a presumption “a defendant is entitled to release on personal recognizance on the condition that the defendant attend all required court proceedings and the defendant does not commit any criminal offense, and complies with all terms of pretrial release.”
¶ 18 While the State argues the circuit court erred when it determined
¶ 19 Under
¶ 20 Here, in determining which conditions of pretrial release would reasonably ensure defendant‘s appearance as well as the safety of any person or the community, the circuit court noted the lack of “any real evidence *** that [defendant] is likely to flee in this case.” The court also considered the risk of obstruction to the criminal justice process, stating defendant “would have no good reason to flee from the courthouse because he would have a series of court dates over time as we work our way through the case that he‘s on conditional discharge for.” See
¶ 21 Based on this record, we cannot say the circuit court abused its discretion when it granted defendant pretrial release pending the hearing on the State‘s petition to revoke his conditional discharge. Accordingly, the State‘s arguments to the contrary are meritless because the court‘s decision was neither “arbitrary, fanciful or unreasonable” nor one where “no reasonable person would agree with the position adopted.” (Internal quotation marks omitted.) Simmons, 2019 IL App (1st) 191253, ¶ 9.
III. CONCLUSION
¶ 22 ¶ 23 For all these reasons, we affirm the judgment of the circuit court.
¶ 24 Affirmed.