People v. Earnest

Defendant appealed from the trial court order granting the State’s petition to deny him pretrial release, arguing that the State lacked the authority to petition for his detention and that the circuit court improperly detained him based on an inadequate proffer from the State. The appellate court vacated the order and remanded for a new detention hearing, finding that trial court did not make any findings regarding whether any condition or combination of conditions would mitigate defendant’s risk of willful flight and that the State merely offered “context” at the hearing, not a proper proffer. (HUTCHINSON and BIRKETT, concurring)