In re Commitment of Winston

2025 IL App (1st) 232214-U
CourtAppellate Court of Illinois
DecidedSeptember 22, 2025
Docket1-23-2214
StatusUnpublished

This text of 2025 IL App (1st) 232214-U (In re Commitment of Winston) 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 Winston, 2025 IL App (1st) 232214-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 232214-U

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).

FIRST DIVISION September 22, 2025 Nos. 1-23-2214 and 1-24-1360 (cons.) ______________________________________________________________________________

IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________

) Appeal from the ) Circuit Court of In re COMMITMENT OF ANDRE WINSTON ) Cook County ) ) No. 12 CR 80014 (The People of the State of Illinois, Petitioner-Appellee, v. ) Andre Winston, Respondent-Appellant). ) The Honorable ) James B. Novy, ) Judge Presiding.

PRESIDING JUSTICE FITZGERALD SMITH delivered the judgment of the court. Justices Lavin and Cobbs concurred in the judgment.

ORDER

¶1 Held: The appellate court affirms the trial court’s judgment entered upon a jury trial finding respondent to be a sexually violent person and the trial court’s order committing him to institutional care in a secure facility.

¶2 Respondent Andre Winston appeals from the judgment of the trial court entered upon a jury’s

determination that he was a sexually violent person in proceedings under the Sexually Violent

Persons Commitment Act (725 ILCS 207/1 et seq. (West 2022)). Respondent argues that the

evidence presented by the State at trial was insufficient to prove beyond a reasonable doubt that

he was a sexually violent person. He also raises multiple arguments that errors occurred at his trial Nos. 1-23-2214 and 1-24-1360 (cons.)

involving evidentiary rulings, closing arguments, and jury instructions. Finally, he raises several

challenges arising out of the trial court’s order committing him to institutional care in a secure

facility, which occurred after the trial court had initially found conditional release to be

appropriate. For the reasons that follow, we affirm the judgment of the trial court.

¶3 I. BACKGROUND

¶4 A. Pretrial Background

¶5 The record before this court reveals that in 1988, respondent was found guilty in a bench trial

in Cook County case number 87-CR-2389 of two counts of aggravated criminal sexual assault,

one count of armed robbery, and one count of armed violence stemming from an incident that

occurred on January 26, 1987, when respondent was 20 years old. Respondent was sentenced to

37 years and 6 months in the Illinois Department of Corrections on that conviction.

¶6 On December 17, 2012, shortly before respondent was scheduled to be released from prison,

the State filed a petition seeking respondent’s involuntary commitment under the Sexually Violent

Persons Commitment Act.

¶7 In February 2013, the trial court conducted a probable cause hearing on the petition and

initially ruled that the State had failed to show probable cause that respondent was a sexually

violent person. This initial ruling was based in part on the trial court’s finding that Ashley Paluska,

Psy.D., the licensed clinical psychologist who testified for the State at the probable cause hearing,

had used “unreliable” evidence in reaching the opinion that respondent met the diagnostic criteria

for the mental disorder of paraphilia not otherwise specified with sexual attraction to

nonconsenting females (hereinafter “paraphilia NOS nonconsent”). Generally speaking, that

diagnosis required a showing of recurrent and intense sexually arousing fantasies, urges, or

behavior involving nonconsenting persons over a period of at least six months. The evidence that

-2- Nos. 1-23-2214 and 1-24-1360 (cons.)

the trial court described as “unreliable” included three offenses for which respondent had been

charged as a juvenile, of which the records had been destroyed by 2013. Thus, Dr. Paluska knew

minimal factual details about these three juvenile cases in reaching the opinion that respondent

had engaged in behavior toward nonconsenting persons over a period of at least six months.

¶8 Respondent’s first juvenile case involved an incident in 1981, when respondent was 15 years

old. He was charged with aggravated criminal sexual abuse, aggravated burglary, burglary, battery,

sexual relations within family, and two counts of miscellaneous delinquency. He was found

delinquent, although it is unknown as to which charges, and placed on probation.

¶9 Respondent’s second juvenile case involved an incident in 1982, when he was 16 years old,

for which he was charged with battery, disorderly conduct, and sexual relations within family.

These charges were dismissed with leave to reinstate.

¶ 10 Respondent’s third juvenile case involved an incident in 1983, when he was 16 years old, for

which he was charged with home invasion, aggravated battery, and burglary. Respondent pled

guilty to the home invasion charge and was sentenced to six years in the Illinois Department of

Corrections (IDOC). No record indicates that there was any sexual component to this 1983 offense

except for a “statement of facts” that was prepared by the office of the Cook County State’s

Attorney as part of respondent’s later case in 1987. That document, which is not contained in the

record on appeal, apparently suggests that respondent had a motive to commit sexual assault as

part of this 1983 incident but was interrupted before any offense of a sexual nature occurred.

¶ 11 As indicated, the trial court initially found following a February 2013 hearing that the State

had failed to show probable cause that respondent was a sexually violent person. The trial court

found that Dr. Paluska’s lack of knowledge of any factual detail about respondent’s three juvenile

adjudications rendered them unreliable as a basis for her diagnosing him with the mental disorder

-3- Nos. 1-23-2214 and 1-24-1360 (cons.)

of paraphilia NOS nonconsent. However, on March 22, 2013, the trial court granted a motion by

the State to reconsider its ruling. In doing so, the trial court reiterated its finding that the lack of

factual information about respondent’s three juvenile cases rendered them unreliable as bases for

Dr. Paluska’s diagnosis. But the trial court found from its review of the transcript that it had

initially misunderstood Dr. Paluska’s testimony that her diagnosis of paraphilia NOS nonconsent

did not rely entirely on the 1987 offense plus the three juvenile adjudications; instead, it also relied

on 10 incidents of sexual misconduct for which respondent had been issued disciplinary tickets by

IDOC between 1990 and 2012. The trial court found that these 10 incidents, which generally fit a

pattern of respondent intentionally exposing himself and masturbating when female correctional

officers were present, had been properly relied upon by Dr. Paluska in diagnosing respondent with

the mental disorder of paraphilia NOS nonconsent. The trial court thus found upon reconsideration

that the State had shown probable cause that respondent was a sexually violent person.

¶ 12 B. Trial

¶ 13 Respondent’s case ultimately proceeded to a two-day jury trial beginning March 8, 2023.

Prior to trial, respondent filed a motion in limine to preclude the State’s witnesses from disclosing

any contents of the “statement of facts” prepared by the State’s Attorney’s office as part of the

1987 case on the grounds that the statements in it were unreliable. A second motion in limine

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2025 IL App (1st) 232214-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-commitment-of-winston-illappct-2025.