In re Commitment of Cehoda

2021 IL App (2d) 190624-U
CourtAppellate Court of Illinois
DecidedSeptember 8, 2021
Docket2-19-0624
StatusUnpublished

This text of 2021 IL App (2d) 190624-U (In re Commitment of Cehoda) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Commitment of Cehoda, 2021 IL App (2d) 190624-U (Ill. Ct. App. 2021).

Opinion

2021 IL App (2d) 190624-U No. 2-19-0624 Order filed September 8, 2021

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(l). ______________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

SECOND DISTRICT ______________________________________________________________________________

In re COMMITMENT OF JAMES CEHODA ) Appeal from the Circuit Court ) of Winnebago County. ) ) No. 16-MR-1113 ) (The People of the State of Illinois, ) Honorable Petitioner-Appellee, v. James Cehoda ) Brendan A. Maher, Respondent-Appellant). ) Judge, Presiding. ______________________________________________________________________________

ORDER JUSTICE BIRKETT delivered the judgment of the court. Justices Hutchinson and Brennan concurred in the judgment.

¶1 Held: The trial court's determination that respondent was a sexually violent person is affirmed where the State proved that respondent’s mental disorder was a congenital or acquired condition and respondent failed to show ineffective assistance of counsel or juror misconduct.

¶2 Respondent, James P. Cehoda, was adjudicated to be a sexually violent person under the

Sexually Violent Persons Commitment Act (Act) (725 ILCS 207/1 et seq. (West 2016)).

Respondent appeals, arguing that the State failed to prove the allegations of its petition beyond a

reasonable doubt, that respondent’s trial counsel was ineffective, and that the jury engaged in juror

misconduct in rendering its verdict. We affirm. 2021 IL App (2d) 190624-U

¶3 I. BACKGROUND

¶4 In 1992, respondent was convicted of two counts of aggravated criminal sexual assault (Ill.

Rev. Stat. 1991, ch. 38, ¶¶ 12-13(a)(1), 12-14(a)(2)) and one count of kidnapping (Ill. Rev. Stat.

1991, ch. 38, § 10-1(a)(1)) and was sentenced to 50 years’ incarceration. On December 7, 2016,

respondent was scheduled to be released. However, on November 28, 2016, the State filed its

petition to commit respondent as a sexually violent person under the Act. The trial court appointed

an assistant public defender to represent respondent and scheduled a probable cause hearing for

November 30, 2016. On that date, respondent’s counsel appeared and filed its motion for

substitution of a judge, effectively postponing the probable cause hearing. On December 14, 2016,

the matter was reassigned to a different judge. Sometime after this date, respondent’s counsel left

the Public Defender’s Office, and a new assistant public defender was assigned the case.

¶5 On February 6, 2017, the parties appeared for a probable cause hearing, but respondent’s

new counsel indicated that he “had the opportunity to speak with [his] client,” and that it was “his

wish to waive [the] probable cause hearing.” As such, the parties stipulated on “a finding of

probable cause.”

¶6 On June 21, 2017, while in custody, respondent filed a pro se demand for discharge from

state custody, based on alleged constitutional violations and established decisions of various

courts. The trial court did not address the motion at that time.

¶7 Respondent’s counsel retained an independent evaluator, Dr. Robert Meyer, who was

appointed to conduct an examination of respondent on October 17, 2017. The report does not

appear in the record. “[A] few weeks” before May 11, 2018, respondent’s counsel left the Public

Defender’s Office. By June 7, 2018, the case was reassigned to another assistant public defender,

-2- 2021 IL App (2d) 190624-U

who would represent respondent throughout the remaining trial court proceedings.

¶8 On December 14, 2018, the parties appeared for a status call and discussed several issues

concerning respondent’s upcoming jury trial. Respondent’s counsel indicated that she did not

anticipate that respondent would call any witnesses during the trial. While she suggested that she

had obtained a report from her own expert—presumably Dr. Meyer—she also indicated that

respondent would not be entering his own report into evidence.

¶9 On January 23, 2019, the parties held a pretrial conference. Respondent’s counsel presented

a motion in limine seeking to exclude witnesses from the courtroom prior to presenting any

testimony, a motion for individual voir dire, and an oral motion seeking permission for respondent

to dress in street clothes and to remain unshackled during the course of the trial. Noting that its

typical procedure for questioning prospective jurors was already “in effect individual voir dire,”

the trial court denied respondent’s counsel’s motion for individual voir dire but granted her

remaining motions.

¶ 10 On April 17, 2019, the parties held their final pretrial conference. Respondent’s counsel

tendered a copy of her proposed jury instructions to the court. The parties went over the State’s

motions in limine, prompting numerous objections from respondent’s counsel. For example,

respondent’s counsel objected to the State’s requests that the trial court preclude respondent from

arguing or implying that respondent’s criminal convictions were invalid, from suggesting that

respondent “has served his time for [his] offenses,” from suggesting that “respondent would be on

parole or supervised release[ ]if not found to be a [s]exually [v]iolent [p]erson,” or from implying

“any information about commitment options such as secure care or conditional release.”

Additionally, respondent’s counsel objected to the State’s requests to preclude respondent from

-3- 2021 IL App (2d) 190624-U

mentioning whether “any actuarial instruments used in this case *** [were] experimental or ***

not generally accepted,” or from opining on the “effectiveness or ineffectiveness of any sex

offender treatment program” or relapse prevention plans. 1 After disposing of the motions in limine,

the parties discussed and finalized their voir dire questions that would be used in selecting a jury.

¶ 11 At the final pretrial conference, respondent asked the court about his earlier demand for

discharge, which he filed in June 2017, pointing out that the trial court “never did answer” the

motion. Respondent’s counsel—who was not assigned to the case at the time of the filing—

informed the judge that she would “take a look at that [motion].” The trial court informed

respondent that “generally speaking, a *** defendant who is represented by an attorney does not

have any authority to file pro se motions and have them adjudicated by the [c]ourt.” Nonetheless,

the court advised respondent that it would address the motion on the morning of his upcoming

trial.

¶ 12 On April 22, 2019, the parties appeared for jury selection. Prior to voir dire, the court asked

respondent, “[Y]ou have received and had an opportunity to look at the independent evaluation

that you sought through your attorney from, I believe, it was Dr. Meyer?” While respondent

couldn’t remember the name of his evaluator, he confirmed that “there was an evaluation.” The

trial court then asked, “[T]he defense did, in fact, secure a written evaluation from Dr. Meyer; is

that correct?” Respondent responded, “Right.” The court then asked, “[Respondent], you and your

attorney have had a chance to review the independent evaluation that was secured on behalf of the

1 Because respondent does not challenge the trial court's rulings on the State's motions in

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Bluebook (online)
2021 IL App (2d) 190624-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-commitment-of-cehoda-illappct-2021.