People v. Andino-Acosta

Defendant appealed from a circuit court order granting the State’s motion to detain him under the Pre-Trial Fairness Act, arguing that the trial court’s written findings did not comply with the Act and that the State failed to prove that no set of conditions could mitigate the danger posed by pretrial release. The appellate court affirmed, finding that the trial court’s oral ruling together with its written findings were sufficient under the Act and that requiring the trial court to transcribe its oral findings into a written order would not serve the interests of justice. The appellate court also found that the trial court’s ruling was not against the manifest weight of the evidence where defendant’s history of domestic violence indicated that monitoring alone would be insufficient to ensure the safety of the victim. (McLAREN and BIRKETT, concurring)