People v. Grandberry

Illinois Appellate Court
Criminal Court
Pre-Trial Fairness Act
Citation
Case Number: 
2024 IL App (3d) 2305446
Decision Date: 
Wednesday, January 10, 2024
District: 
3d Dist.
Division/County: 
DuPage Co.
Holding: 
Reversed and remanded.
Justice: 
ALBRECHT

Defendant was indicated on two counts of aggravated battery of a peace officer and six counts of aggravated battery of a nurse. Defendant appealed from a trial court order granting the State’s motion for pre-trial detention, arguing that the court abused its discretion when it found that she was charged with a detainable offense. The appellate court reversed and remanded, finding that where the language of the Pre-Trial Release Act identified a subset of aggravated battery as a forcible felony, later reference to “other felony” must refer to felonies other than aggravated battery, not a different subset of aggravated battery and, as a result, that the trial court abused its discretion in granting the State’s petition. (HOLDRIDGE and PETERSON, concurring)