In re Commitment of McCormack

2021 IL App (1st) 181930-U
CourtAppellate Court of Illinois
DecidedMay 17, 2021
Docket1-18-1930
StatusUnpublished
Cited by8 cases

This text of 2021 IL App (1st) 181930-U (In re Commitment of McCormack) 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 McCormack, 2021 IL App (1st) 181930-U (Ill. Ct. App. 2021).

Opinion

2021 IL App (1st) 181930-U No. 1-18-1930 Order filed May 17, 2021

First Division

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________ IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________ In re COMMITMENT OF DANIEL MCCORMACK ) Appeal from the ) Circuit Court of (The People of the State of Illinois, ) Cook County. ) Petitioner-Appellee, ) No 09 CR 80006 v. ) ) Honorable Daniel McCormack, ) Dennis J. Porter, ) Judge, presiding. Respondent-Appellant). )

. JUSTICE HYMAN delivered the judgment of the court. Presiding Justice Walker and Justice Pierce concurred in the judgment.

ORDER

¶1 Held: Reversed trial court’s order of commitment under the Sexually Violent Persons Commitment Act where the State failed to prove McCormack’s mental disorder renders him substantially likely to reoffend.

¶2 Daniel McCormack pled guilty to a series of sexual assault charges and received concurrent

prison terms for each. Before his release from custody at the Illinois Department of Corrections

(IDOC), the State had him evaluated under the Sexually Violent Persons Commitment Act. See 725 ILCS 207/1 et seq. (West 2020). The State’s expert, Dr. Angelique Stanislaus, testified that

McCormack met the criteria for civil commitment under the Act. McCormack’s expert, Dr.

Raymond Wood, found that McCormack did not meet the criteria for commitment under the Act

relying on nearly identical information to Stanislaus. The trial court found McCormack qualified

as a sexually violent person beyond a reasonable doubt and ordered him committed to a secure

treatment facility.

¶3 McCormack now argues that the State failed to prove he qualifies as a sexually violent

person. He challenges the State’s proof on two grounds: the State failed to prove that any mental

disorder McCormack may have (i) creates a risk he may reoffend and (ii) creates a substantial

probability that McCormack will commit future acts of sexual violence even if his disorder creates

some risk he may reoffend. See id. §15(b) (setting out elements State must allege and prove). We

agree with McCormack’s latter argument and reverse the trial court’s order of commitment.

¶4 Background

¶5 At a bench trial, the State called Stanislaus, who explained her education, qualifications,

and experience evaluating respondents under the Act. The trial court qualified her as an expert in

forensic psychiatry with a focus on evaluating, diagnosing, and assessing the risk of sexually

violent persons.

¶6 Stanislaus evaluated McCormack in 2009 and updated her evaluations in 2011 and 2013.

She reviewed and relied on a host of documentary evidence, including investigative reports and

police reports related to the underlying criminal conduct. She also reviewed IDOC records and

Quackenbush’s report of his initial evaluation of McCormack. As part of her initial evaluation in

2009, Stanislaus went to Jacksonville Correctional Center to meet with McCormack who “stated

that, in a very pleasant manner, that he *** cannot participate in the interview because he had civil

2 litigation pending.” Before she left, however, McCormack told Stanislaus that he had participated

in substance abuse treatment while incarcerated.

¶7 In 2011, Stanislaus reviewed more than 6,000 pages of documents from the Office of

Professional Responsibility of the Archdiocese of Chicago. The documents contained “more

allegations from several other *** underage males.” Stanislaus also reviewed additional

investigative reports related to the underlying offenses, DHS treatment records, and other records

of psychological treatment. Stanislaus made no effort to interview McCormack in 2011 because

“he was given an opportunity the first time.” She explained that it is a generally accepted practice

in her field to update evaluations based solely on documentary records. In 2013 Stanislaus updated

her report because the diagnostic manual changed from the DSM-4-TR to the DSM-5. She did not

evaluate any additional records, simply updating the 2011 report to reflect new diagnostic

language.

¶8 In all three reports, Stanislaus concluded McCormack met the criteria for commitment

under the Act.

¶9 Stanislaus also testified to the details of the offenses leading to McCormack’s guilty pleas.

We do not recount those details here because, for this appeal, the parties do not dispute that

McCormack was convicted of an offense that qualifies as a “sexually violent offense” under the

Act. For now it is enough to say that all five offenses involved minor male victims who knew

McCormack as either a teacher, coach, or priest.

¶10 To complete her evaluation, Stanislaus consulted the “authoritative text” on the diagnosis

of mental illness or disorder, the DSM-5. She concluded within a reasonable degree of psychiatric

certainty that McCormack had “pedophilic disorder, sexually attracted to males.” Stanislaus

explained the criteria for pedophilic disorder and compared those criteria to McCormack’s

3 criminal behavior. Stanislaus acknowledged that McCormack had not committed any new sexual

offenses since 2006 but explained that “[i]f you have a deviant sexual interest in boys, it is pretty

present, pretty much throughout your life.” She also noted that McCormack’s pedophilic disorder

was not likely to have changed because he had not participated in sex offender treatment.

¶11 Stanislaus explained that pedophilic disorder affected McCormack’s ability to control his

sexually violent behavior and pointed to his pattern of reoffending even after he came under

supervision due to complaints about his inappropriate conduct.

¶12 Based on other diagnostic instruments, Stanislaus concluded McCormack had a

statistically “average risk” of reoffending. Looking then to factors unique to McCormack, she

found his long-term preference for boys in the prepubescent age group to be a risk factor. She also

included “the presence of emotional congruence with children,” meaning McCormack showed he

felt “much more comfortable interacting with children” rather than adults. Stanislaus considered

McCormack’s “sexual preoccupation” based on his actions taken with multiple victims and his

willingness to touch his victims even in public places inappropriately. As mentioned, Stanislaus

considered McCormack’s willingness to reoffend even after being told he was under supervision.

Stanislaus found indications that McCormack engaged in “sexualized coping” by increasing the

pace of his offenses when under pressure and abused his position of power as a priest to abuse his

victims. Finally, Stanislaus found McCormack’s lack of an intimate relationship contributed to his

risk of reoffending.

¶13 After considering all of the statistical instruments and factors unique to McCormack,

Stanislaus concluded that reoffending was “substantially probable, meaning much more likely than

not.”

4 ¶14 McCormack called Dr. Raymond Wood to testify. Like Stanislaus, the court qualified

Wood as an expert in sex offender treatment and evaluation, including risk assessment and

diagnosis.

¶15 Wood evaluated McCormack in 2010. He reviewed a report from IDOC evaluator Dr. Ray

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In re Commitment of Winston
2025 IL App (1st) 232214-U (Appellate Court of Illinois, 2025)
In re Commitment of Boaz
2025 IL App (5th) 220642-U (Appellate Court of Illinois, 2025)
In re Commitment of Floyd
2025 IL App (1st) 230047-U (Appellate Court of Illinois, 2025)
In re Commitment of Mitts
2025 IL App (1st) 230821-U (Appellate Court of Illinois, 2025)
In re Commitment of Gavin
2024 IL App (1st) 230246 (Appellate Court of Illinois, 2024)
In re The Commitment of Pieroni
2024 IL App (1st) 230028-U (Appellate Court of Illinois, 2024)
In re Commitment of Jackson
2023 IL App (1st) 221303-U (Appellate Court of Illinois, 2023)
In re Commitment of Holt
2022 IL App (1st) 210402 (Appellate Court of Illinois, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
2021 IL App (1st) 181930-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-commitment-of-mccormack-illappct-2021.