People v. Samuels

Defendant, who was charged with multiple criminal felony offenses as well as violating the conditions of his probation, appealed from a trial court order denying him pretrial release. Defendant argued on appeal that he was not eligible for detention on the probation-violation case because he had already pleaded guilty and been sentenced to probation and that in the two additional cases that the State failed to prove that he committed a qualifying offense. The appellate court affirmed, finding that the State had met its burden of proving that defendant had committed a detainable offense. (HETTEL, concurring and McDADE, concurring in part and dissenting in part)