Illinois Appellate Court
Criminal Court
Plain Error Review
Defendant, who was charged with aggravated battery of a police officer and obstructing a police officer, appealed from a trial court order denying her pretrial release, arguing that the State did not charge her with a detainable offense and that pretrial release could not be revoked because she had not yet been released on any of the charges in the current case. The appellate court, applying a plain error standard, affirmed the trial court. The appellate court explained that any alleged error in the detention proceedings did not rise to the level of structural error. (ZENOFF and LANNERD, concurring)