In re Commitment of James

2025 IL App (4th) 240733-U
CourtAppellate Court of Illinois
DecidedMarch 11, 2025
Docket4-24-0733
StatusUnpublished

This text of 2025 IL App (4th) 240733-U (In re Commitment of James) 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 James, 2025 IL App (4th) 240733-U (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (4th) 240733-U This Order was filed under FILED March 11, 2025 Supreme Court Rule 23 and is NO. 4-24-0733 Carla Bender not precedent except in the 4th District Appellate limited circumstances allowed IN THE APPELLATE COURT Court, IL under Rule 23(e)(1). OF ILLINOIS

FOURTH DISTRICT

In re COMMITMENT OF JAMES JAMES JR. ) Appeal from the ) Circuit Court of (The People of the State of Illinois, ) Henry County Petitioner-Appellee, ) No. 20MR84 v. ) James James Jr., ) Honorable Respondent-Appellant). ) Colby G. Hathaway, ) Judge Presiding.

JUSTICE LANNERD delivered the judgment of the court. Justices Knecht and DeArmond concurred in the judgment.

ORDER

¶1 Held: The appellate court affirmed the trial court’s judgment.

¶2 In May 2020, the State filed a petition alleging respondent, James James Jr., was a

sexually violent person (SVP) as defined by the Sexually Violent Persons Commitment Act (Act)

(725 ILCS 207/1 et seq. (West 2020)) and asking the trial court for an order of commitment

pursuant to section 40 of the Act (id. § 40). In April 2024, the court found the State proved beyond

a reasonable doubt that respondent was an SVP as defined by section 5(f) of the Act (725 ILCS

207/5(f) (West 2022)) and ordered respondent to be committed to the Illinois Department of

Human Services (DHS) Treatment and Detention Facility (TDF). Respondent appeals, arguing he

did not have a qualifying mental disorder under the Act, the State did not prove beyond a

reasonable doubt he was an SVP, and the Act was applied to him in an unconstitutional manner.

We affirm. ¶3 I. BACKGROUND

¶4 On May 26, 2020, the State filed a petition to commit respondent to a TDF because

he was an SVP. The petition noted Dr. Robert Brucker Jr. diagnosed respondent with “Other

Specified Personality Disorder, with Antisocial Traits,” which is a congenital or acquired condition

affecting respondent’s emotional or volitional capacity that predisposes him to commit acts of

sexual violence. The State alleged respondent was dangerous to others because one or more of his

mental disorders create a substantial probability that he would engage in acts of sexual violence.

¶5 That same day, after reviewing the State’s petition and attached exhibits and

determining cause existed to believe respondent was eligible for commitment under section 35(f)

of the Act (725 ILCS 207/35(f) (West 2020)), the trial court ordered respondent to be detained. On

May 28, 2020, the court entered a probable cause finding and order, ordering respondent to be

detained and undergo an evaluation to determine whether he was an SVP.

¶6 In March 2024, a bench trial was held on the State’s petition to commit respondent

as an SVP under the Act. The trial court heard from Dr. Brucker and Dr. Nicole Hernandez, who

the parties stipulated were expert witnesses, and no other witnesses testified.

¶7 A. Testimony of Dr. Brucker

¶8 The State called Dr. Brucker, a licensed clinical psychologist and sex offender

evaluator with a doctorate degree in clinical psychology. According to his testimony, he was

familiar with the Act, first worked with sex offenders in 1995, and started working at the TDF in

May 2000. Since 2011, he had performed SVP evaluations for both the Office of the Illinois

Attorney General (AG’s Office) and respondents. The AG’s Office asked him for a second opinion

as to whether respondent met the criteria for commitment as an SVP. He interviewed respondent

for 4 hours and 30 minutes on April 23, 2020. This was his only interview with respondent, but he

-2- completed multiple evaluations of respondent and reviewed documentation from the TDF facility

where respondent was held. He indicated he was confident additional interviews would not have

provided substantially new information.

¶9 Dr. Brucker testified he completed four reports in this case—dated April 29, 2020,

June 29, 2021, January 29, 2022, and July 20, 2023—examining whether respondent continued to

meet the definition of an SVP under the Act. He determined respondent remained an SVP.

Throughout this case, he reviewed reports from other evaluators, police reports, court documents,

evaluations, sex offender evaluations, disciplinary records, mental health records, medical records,

and documents from the TDF (including disciplinary records, treatment records, medical records,

treatment plans, and other evaluations conducted at the TDF).

¶ 10 Regarding respondent’s criminal history, Dr. Brucker testified respondent was

arrested for disorderly conduct at 17 and setting grass on fire when he was 18. Respondent was

sentenced to a stayed 30-day term in the county jail and a 1-year term of conditional discharge.

During that year, two petitions to revoke respondent’s conditional discharge were filed because he

was behind in paying his probation fees. On January 30, 2009, a woman reported respondent

committed sexual offenses against her two-year-old daughter and three-year-old son while

babysitting them. Although Dr. Brucker noted respondent had consistently denied engaging in this

behavior, he was convicted in that case and sentenced to 180 days in jail and 4 years’ probation.

¶ 11 Respondent was released from jail on September 16, 2009. Less than a week later,

two inmates at the jail told investigators respondent had forced oral and anal sex on one of the

inmates, K.H, who did not want to engage in those acts but was unable to stop respondent. The

other inmate, O.G., witnessed respondent being physically aggressive toward K.H. and forcing

K.H. to take part in oral and anal sex on multiple occasions. Both K.H. and O.G. indicated

-3- respondent threatened the men with serious injury or death if they told anyone what he had done.

When Dr. Brucker asked respondent about these allegations, respondent acknowledged acting

aggressively toward the men and threatening them but could not remember what happened with

K.H. regarding the oral and anal sex allegations. Dr. Brucker indicated respondent appeared to be

ashamed or bothered by the allegations. Respondent admitted forcing K.H. to “stick a carrot up his

ass” because he was bored and K.H. was someone he could pick on. After finding out O.G.

provided a videotaped interview, respondent acknowledged he had K.H. perform oral sex on him

and had anal sex with K.H. but claimed these were consensual acts. However, he acknowledged

knowing both O.G. and K.H. were very scared of him.

¶ 12 On September 23, 2009, respondent, a registered sex offender, was found near

Kewanee High School while children were present in the neighborhood and students were in the

parking lot. He was transported to the Henry County Sheriff’s Office. Dr. Brucker testified

respondent provided inconsistent explanations for why he was near the school. He indicated he did

not know he was not allowed to be near the school but also told people he thought he would only

receive a warning because it was a first offense. The State charged respondent with unlawful

loitering and unlawful presence in a school zone. He was convicted and sentenced to three years

in prison.

¶ 13 Dr. Brucker testified respondent was released from prison in November 2011. In

July 2012, he was arrested in Macomb for a sex offender registration violation. In February 2013,

he was charged in Henry County for the same thing.

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Related

Kansas v. Hendricks
521 U.S. 346 (Supreme Court, 1997)
People v. Wilson
827 N.E.2d 416 (Illinois Supreme Court, 2005)
In re Commitment of Fields
2014 IL 115542 (Illinois Supreme Court, 2014)
In re Detention of Stanbridge
2012 IL 112337 (Illinois Supreme Court, 2012)
People v. Thompson
2015 IL 118151 (Illinois Supreme Court, 2016)
In re The Detention of White
2016 IL App (1st) 151187 (Appellate Court of Illinois, 2016)
Accettura v. Vacationland, Inc.
2019 IL 124285 (Illinois Supreme Court, 2019)
In re Commitment of Gavin
2019 IL App (1st) 180881 (Appellate Court of Illinois, 2019)

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Bluebook (online)
2025 IL App (4th) 240733-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-commitment-of-james-illappct-2025.