NOTICE 2025 IL App (4th) 250098-U This Order was filed under FILED Supreme Court Rule 23 and is June 24, 2025 NO. 4-25-0098 not precedent except in the Carla Bender limited circumstances allowed 4th District Appellate under Rule 23(e)(1). IN THE APPELLATE COURT Court, IL
OF ILLINOIS
FOURTH DISTRICT
THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) Whiteside County NAMIR I. BUCK, ) No. 25CC1 Defendant-Appellant. ) ) Honorable ) Jennifer Rangel-Kelly, ) Judge Presiding.
JUSTICE ZENOFF delivered the judgment of the court. Justices Steigmann and Lannerd concurred in the judgment.
ORDER
¶1 Held: The appellate court affirmed an order holding defendant in direct criminal contempt where (1) the trial court personally observed the contemptuous conduct and (2) the contempt order was conducive to appellate review.
¶2 Defendant, Namir I. Buck, appeals an order holding him in direct criminal contempt
and sentencing him to six months in jail. We affirm.
¶3 I. BACKGROUND
¶4 Buck was the defendant in Whiteside County case No. 23-CF-226. His conduct in
connection with that case on November 20, 2024, led to him being held in direct criminal contempt
in the instant action, case No. 25-CC-1. The record on appeal does not include the common law
record or any reports of proceedings pertaining to case No. 23-CF-226. However, an affidavit in
the record prepared by a court reporter certifies that there were no proceedings reported in that
case on November 20, 2024. ¶5 On January 3, 2025, the trial court held contempt proceedings in case No. 25-CC-
1. Although Buck was present with counsel that day for his underlying criminal case, the court
stated that it had “business with” Buck that did not involve counsel’s representation. The court
then said:
“Mr. Buck, when you were last before this Court back on November 20th
your actions caused this Court to find you in direct criminal contempt.
You were advised that you had an arrest warrant by law enforcement. You
fled this courtroom[,] injuring persons in the courtroom, gave chase, and fled from
law enforcement officers and ignored their commands, all in the presence of this
Court and so I’m finding you in direct criminal contempt.”
The court informed Buck that he could make a statement in allocution and that possible penalties
included a fine of up to $500 and up to six months in jail.
¶6 Buck made a statement in allocution. He indicated that he was trying to right his
wrongs and work on himself while incarcerated for the past 45 days. He understood that he “was
wrong for jolting out of the courtroom” but said he did so out of fear, as a fight-or-flight reaction.
He apologized “to the Court and to whoever I injured in that moment.” He knew he “was 100
percent completely wrong” and expressed his desire for “a second chance at life.”
¶7 The trial court sentenced Buck to six months in jail for direct criminal contempt.
The court explained that this would be a lesson to Buck that when he is told he has an arrest warrant
and is going to be placed under arrest, he is “not free to leave,” and fleeing will not be tolerated.
The court added: “It is a complete disregard for law enforcement’s authority and for the respect
this Court deserves in any courtroom that you are in anywhere.”
¶8 The trial court also entered a written contempt order on January 3, 2025. The court
-2- made the following findings:
“1. This Court has jurisdiction over the subject matter and the parties.
2. On or about Nov. 20, 2024, [Buck] was advised in open court of his arrest
on an outstanding warrant and fled from the courtroom and bailiffs. Law
enforcement personnel gave chase, and [Buck] failed to comply with law
enforcement’s commands to stop running, and fled the Whiteside County
Courthouse. [Buck] continued to flee onto the public roadway and was eventually
taken into custody by law enforcement on a valid arrest warrant.
3. The Court finds that the conduct of [Buck], which occurred in the
presence of this Court, while the Court was in open session, impeded and
interrupted this Court’s proceedings, lessened the dignity of this court, and tended
to bring the administration of justice into disrepute.
4. [Buck] was given an opportunity to make a statement in allocution, and
did so.”
Thus, the court found Buck to be in direct criminal contempt “by reason of his willful and
contemptuous conduct.” The court sentenced Buck to six months in jail, “commencing instanter.”
¶9 A docket entry from January 3, 2025, added that Buck would receive day-for-day
credit against his sentence.
¶ 10 On January 28, 2025, Buck filed a pro se notice of appeal in case No. 23-CF-226,
specifying his intent to appeal the contempt order entered on January 3, 2025. We appointed the
Office of the State Appellate Defender to represent Buck. Through counsel, Buck sought leave to
amend his notice of appeal to reference the correct case number. We allowed that motion.
¶ 11 II. ANALYSIS
-3- ¶ 12 A. Mootness
¶ 13 The parties do not address whether this appeal might be moot due to Buck
completing his jail sentence. Upon considering the issue ourselves, we determine that this appeal
is not moot, despite Buck having likely already completed his sentence.
¶ 14 “A judgment of contempt which imposes a fine or sentence of imprisonment is
appealable, enabling the reviewing court to consider the propriety of the order.” In re J.L.D., 178
Ill. App. 3d 1025, 1029 (1989). “However, an appeal from a contempt order is ordinarily
considered moot where the party held in contempt has served the sentence.” J.L.D., 178 Ill. App.
3d at 1030. One exception is that even if a challenge to the sentence would be moot, a contemnor
may challenge his or her conviction, as “ ‘[n]ullification of a conviction may hold important
consequences for a defendant.’ ” People v. Cordray, 2022 IL App (4th) 220413-U, ¶ 17 (quoting
In re Christopher K., 217 Ill. 2d 348, 359 (2005)); see People v. Edwards, 2024 IL App (4th)
231329-U, ¶ 16 (addressing a contemnor’s challenge to his conviction after he completed his
sentence).
¶ 15 Although it seems likely that Buck has already served his sentence, the record does
not reflect when or if he was released from custody. We also consider that Buck challenges the
propriety of the contempt finding, the nullification of which may have important consequences for
him. See Cordray, 2022 IL App (4th) 220413-U, ¶ 17; Edwards, 2024 IL App (4th) 231329-U,
¶ 16. Under these circumstances, we may consider the merits of Buck’s appeal.
¶ 16 B. Challenge to the Judgment
¶ 17 On appeal, Buck challenges the judgment on two bases: (1) the trial court punished
him for conduct the court did not personally observe, without the required procedural safeguards
and (2) alternatively, the contempt order is insufficient to allow appellate review. We will address
-4- the issues in that order because Buck presents them this way and his arguments are interrelated.
¶ 18 1. Whether the Trial Court Punished Buck for Conduct
the Court Did Not Personally Observe, Without the Required
Procedural Safeguards
¶ 19 Buck argues that the trial court erroneously jailed him “for behavior that appears to
have occurred outside of the presence of the *** court, without any of the required procedural
safeguards.” Buck reasons as follows. The record in a case involving direct criminal contempt
must reflect that the court punished contemnor based on facts “within the court’s observation and
knowledge.” Here, the court was “unlikely to have personally observed” some of the conduct
mentioned in the written contempt order—specifically, anything “that may have followed [Buck’s]
egress from the courtroom” on November 20, 2024. Rather, the court “would have had to rely on
third-party accounts” to make findings about what occurred after Buck left the courtroom, and the
record does not show how the court acquired such knowledge. Moreover, although the court
mentioned in its oral ruling that it observed Buck injure people inside the courtroom, that fact was
not reiterated in the written contempt order and thus does not appear to be a basis “on which the
court relied in finding [Buck] in contempt.” “Because the purportedly contumacious behavior
occurred outside of the presence of the court,” Buck was entitled to “the full procedural safeguards
of indirect contempt proceedings,” including “the right to counsel, presumption of innocence, and
a contested hearing at which his guilt must be proven beyond a reasonable doubt.” He was not
accorded such protections, so we should reverse his conviction.
¶ 20 The State responds that although the trial court provided “the full narrative”
surrounding Buck’s conduct on November 20, 2024, the record shows that the court held Buck in
contempt for behavior occurring in the court’s presence. According to the State, we must presume
-5- that the court understood the law regarding direct criminal contempt and applied those rules
properly. The State contrasts the circumstances here to some of the cases cited by Buck, in which
the records affirmatively showed that trial courts lacked personal knowledge of the contumacious
conduct.
¶ 21 Courts are vested with the inherent power to preserve their dignity through
contempt proceedings. People v. Sheahan, 150 Ill. App. 3d 572, 575 (1986). To that end, courts
may sanction individuals for criminal contempt “for the purpose of punishing past misconduct.”
In re Marriage of Betts, 200 Ill. App. 3d 26, 43 (1990). “ ‘Criminal contempt of court has been
generally defined as conduct which is calculated to embarrass, hinder or obstruct a court in its
administration of justice or derogate from its authority or dignity, thereby bringing the
administration of law into disrepute.’ ” People v. Hixson, 2012 IL App (4th) 100777, ¶ 11 (quoting
People v. Javaras, 51 Ill. 2d 296, 299 (1972)).
¶ 22 There are two categories of criminal contempt: direct and indirect. People v. L.A.S.,
111 Ill. 2d 539, 543 (1986). “A finding of direct criminal contempt is ‘strictly restricted to acts and
facts seen and known by the court, and no matter resting upon opinions, conclusions, presumptions
or inferences should be considered.’ ” In re Contempt of Turner, 2016 IL App (4th) 160245, ¶ 24
(quoting People v. Simac, 161 Ill. 2d 297, 306 (1994)). “Direct criminal contempt may occur in
either of two ways: (1) the contemptuous acts are personally observed by the judge or (2) the
contemptuous acts are committed outside the immediate physical presence of the judge but within
an integral part of the court, i.e., the circuit clerk’s office.” Hixson, 2012 IL App (4th) 100777,
¶ 12. By contrast, indirect criminal contempt involves conduct “ ‘which in whole or in an essential
part occurred out of the presence of the court, is not admitted, and which is therefore dependent
for its proof upon evidence of some kind.’ ” L.A.S., 111 Ill. 2d at 543 (quoting People v. Harrison,
-6- 403 Ill. 320, 324 (1949)).
¶ 23 Classifying contemptuous conduct accurately is important because it dictates the
nature of the contemnor’s due process rights. “Where a direct contempt is committed in open court
it is competent for the judge to proceed upon his personal knowledge of the facts and to punish the
offender summarily without entering any rule against him and without hearing any evidence.”
People v. Jashunsky, 51 Ill. 2d 220, 224 (1972). In other words, the contemnor in such instance is
not entitled to “the usual procedural-due-process safeguards.” Hixson, 2012 IL App (4th) 100777,
¶ 13. But where criminal contempt is indirect, the contemnor is entitled to far greater safeguards,
including:
“ ‘(1) notice of the nature of the contempt charges; (2) an opportunity to answer the
alleged charges; (3) right to a hearing; (4) the privilege against self-incrimination;
(5) the presumption of innocence; (6) the right to be proved guilty beyond a
reasonable doubt; (7) right to counsel (and to appointed counsel if indigent);
(8) right to confront and cross-examine witnesses; (9) right to be personally present
at trial; (10) right to testify or to remain silent; (11) right to compulsory process for
obtaining witnesses; and (12) right to present the testimony of witnesses favorable
to his or her defense.’ ” Turner, 2016 IL App (4th) 160245, ¶ 28 (quoting Hixson,
2012 IL App (4th) 100777, ¶ 19).
These same heightened safeguards are required in cases of direct criminal contempt where the
contemptuous conduct occurs within an integral part of the court but outside the judge’s immediate
physical presence. Turner, 2016 IL App (4th) 160245, ¶ 28. As an example, where spectators at a
jury trial handed out materials in the courtroom that contained advocacy relating to the issues in
the case, but the trial court did not personally observe those contemptuous acts, the Fourth District
-7- held that the trial court could not adjudicate the contemnors in direct criminal contempt without
according them the enhanced due process protections associated with indirect criminal contempt.
Turner, 2016 IL App (4th) 160245, ¶¶ 26, 29-30.
¶ 24 Here, the trial court held Buck in direct criminal contempt. “On appeal, the standard
of review for direct criminal contempt is whether there is sufficient evidence to support the finding
of contempt and whether the judge considered facts outside of the judge’s personal knowledge.”
Simac, 161 Ill. 2d at 306. For the following reasons, we determine that the court properly held
Buck in direct criminal contempt.
¶ 25 On January 3, 2025, the court stated on the record:
“Mr. Buck, when you were last before this Court back on November 20th
your actions caused this Court to find you in direct criminal contempt.
You were advised that you had an arrest warrant by law enforcement. You
fled this courtroom[,] injuring persons in the courtroom, gave chase, and fled from
law enforcement officers and ignored their commands, all in the presence of this
After Buck made a statement in allocution, the court sentenced him to six months in jail. The court
said that this would be a lesson to Buck that when he is told he has an arrest warrant and is going
to be placed under arrest, he is “not free to leave,” and fleeing will not be tolerated. The court
added, “It is a complete disregard for law enforcement’s authority and for the respect this Court
deserves in any courtroom that you are in anywhere.”
¶ 26 It is clear from this oral ruling that the trial court held Buck in direct criminal
contempt based only on behaviors that the court personally witnessed and of which the court had
personal knowledge. Plainly, the basis for the contempt finding was that the court saw Buck flee
-8- the courtroom to avoid arrest, ignoring officers’ commands and injuring people in the process.
Although the record does not reflect who was injured, how gravely, or exactly how the injuries
occurred, the facts detailed by the court adequately justify the contempt finding. See People v.
Brown, 235 Ill. App. 3d 945, 947-48 (1992) (a defendant who fled a courtroom to avoid being
remanded to jail received a 180-day jail sentence for direct criminal contempt); People v. Ellis, 40
Ill. App. 3d 370, 370 (1976) (a defendant who fled a courtroom and was caught on the courthouse
stairs received a 6-month sentence for direct criminal contempt).
¶ 27 Reviewing the trial court’s written contempt order reinforces our conclusion that
the court properly held Buck in direct criminal contempt based only on facts within its personal
knowledge. In paragraph two of its order, the court wrote:
“2. On or about Nov. 20, 2024, [Buck] was advised in open court of his
arrest on an outstanding warrant and fled from the courtroom and bailiffs. Law
enforcement personnel gave chase, and [Buck] failed to comply with law
enforcement’s commands to stop running, and fled the Whiteside County
Courthouse. [Buck] continued to flee onto the public roadway and was eventually
taken into custody by law enforcement on a valid arrest warrant.”
Focusing on this paragraph of the order, Buck suggests it is unlikely that the court personally saw
him enter the public roadway or personally saw the subsequent arrest. However, the next part of
the order makes it clear that the court held Buck in direct criminal contempt only for behavior that
the court personally witnessed. Specifically, paragraph three said:
“3. The Court finds that the conduct of [Buck], which occurred in the
presence of this Court, while the Court was in open session, impeded and
interrupted this Court’s proceedings, lessened the dignity of this court, and tended
-9- to bring the administration of justice into disrepute.” (Emphasis added.)
In other words, the court expressly confirmed in the order that the basis for the contempt finding
was limited to behavior that the court personally witnessed. Additionally, the court’s oral findings
inform our interpretation of the written order, so we reject Buck’s contention that a few statements
in the written order fundamentally changed the nature of the contempt proceedings from direct to
indirect.
¶ 28 Buck insists that the contempt here was indirect rather than direct because it is
possible or likely that the trial court did not personally witness the events that occurred after Buck
left the courtroom. The premise of this argument contradicts the well-settled notion that courts are
presumed to know the law and apply it properly, absent affirmative indications in the record to the
contrary. People ex rel. City of Chicago v. Le Mirage, Inc., 2013 IL App (1st) 093547, ¶ 136.
Accordingly, we cannot reverse the judgment on the mere suspicion that the court might not have
observed something personally. Moreover, events occurring after Buck left the courtroom were
not essential to the finding of contempt, as the court personally witnessed Buck flee the courtroom
to avoid arrest and saw the resulting injuries. See L.A.S., 111 Ill. 2d at 543 (“Indirect criminal
contempt is contemptuous conduct ‘which in whole or in an essential part occurred out of the
presence of the court, is not admitted, and which is therefore dependent for its proof upon evidence
of some kind.’ ”) (quoting Harrison, 403 Ill. at 324).
¶ 29 Even were we to assume that the trial court was not present when Buck was arrested
and did not personally observe Buck entering the roadway, that would not change the result of this
appeal. Case law supports the notion that superfluous references to facts outside a court’s personal
knowledge will not undermine an otherwise valid direct-criminal-contempt order that was
appropriately based on the court’s personal observations. In Cordray, 2022 IL App (4th) 220413-
- 10 - U, ¶ 8, a trial judge perceived that the defendant was inebriated at his sentencing hearing, so she
continued the hearing and ordered the defendant to take a drug test. When the matter next returned
to court, a probation officer informed the court that the defendant tested positive for cocaine,
methamphetamine, and alcohol two days after the last court date. Cordray, 2022 IL App (4th)
220413-U, ¶ 9. In addition to sentencing the defendant for the underlying offense, the court
sentenced him to 180 days in jail for direct criminal contempt. Cordray, 2022 IL App (4th) 220413-
U, ¶ 10. As part of explaining the basis for contempt in its oral ruling, the court said: “ ‘You
brought the administration of justice in this courtroom into disrepute and are guilty *** of direct
criminal contempt for showing up for your sentencing hearing in a condition under the influence
of methamphetamine, cocaine, that was in your system 48 hours after you were in court.’ ”
Cordray, 2022 IL App (4th) 220413-U, ¶ 10. On appeal, the defendant challenged the contempt
order on the basis that “his allegedly contemptuous behavior did not sufficiently take place within
the trial court’s presence because the court ‘did not personally observe the taking of illegal
drugs.’ ” Cordray, 2022 IL App (4th) 220413-U, ¶ 14. We rejected this argument and affirmed the
judgment, reasoning in part that “the [trial] court’s brief reference with respect to the specific
substances defendant tested positive for was nothing more than unnecessary surplusage because
the court observed defendant’s behavior firsthand at the [original sentencing] hearing and needed
no extrinsic evidence to find defendant in direct criminal contempt.” Cordray, 2022 IL App (4th)
220413-U, ¶ 21.
¶ 30 Cordray illustrates that extraneous references to facts beyond a court’s personal
knowledge do not inherently nullify an otherwise valid direct-criminal-contempt order. Here, the
argument in support of an affirmance is even more compelling than in Cordray. In Cordray, the
appellate court affirmed even though the record showed that the trial court (1) received some
- 11 - information from a third party (the probation officer’s representations about the results of the drug
test) and (2) expressly mentioned that information when identifying the contemptuous conduct.
Cordray, 2022 IL App (4th) 220413-U, ¶¶ 9-10. Here, there is no affirmative proof in the record
that the court received information from a third party, and the language in both the court’s oral
ruling and its written contempt order confirms that it relied only on its personal observations.
¶ 31 Buck cites cases where the records on appeal affirmatively showed that the trial
courts lacked personal knowledge of all facts necessary to make findings of direct criminal
contempt. See, e.g., People v. Tomashevsky, 48 Ill. 2d 559, 565 (1971) (explaining that principles
of direct criminal contempt did not apply where a judge heard laughter in a crowded courtroom
but did not personally know whether the two contemnors laughed). Tomashevsky and other similar
cases are distinguishable, as the court’s oral ruling and written order here make it clear that the
court personally witnessed Buck engaging in behavior that was undeniably contemptuous—fleeing
the courtroom to avoid arrest.
¶ 32 Buck also submits that the trial court did not rely on the injuries to people in the
courtroom as part of the basis for holding him in contempt, given that the written order made no
mention of injuries. This argument is unavailing. Even if there were a conflict between the oral
and written rulings in that regard, the oral ruling would prevail. See People v. Watkins-Romaine,
2025 IL 130618, ¶ 38 (noting that in the event of a conflict, a court’s oral statement controls over
the written judgment).
¶ 33 Accordingly, we hold that the trial court properly held Buck in direct criminal
contempt without affording him the much broader procedural protections attendant to cases
involving indirect criminal contempt.
¶ 34 2. Whether the Contempt Order Is Conducive to Appellate Review
- 12 - ¶ 35 Alternatively, Buck argues that the trial court denied him due process of law by
jailing him for direct criminal contempt “without laying out the necessary facts giving rise to that
finding in either a written order or in a verbatim transcript.” Thus, he maintains that the appellate
court “cannot determine the propriety of summary direct contempt proceedings in general or the
sentence imposed in particular.” The premises of Buck’s claim are very similar to what he argued
in support of the preceding issue. Specifically, he proposes that (1) we cannot ascertain for which
behaviors the court held him in contempt and sentenced him, (2) the basis for contempt may have
been facts that the court did not personally observe, and (3) the court did not sufficiently detail
how it was personally aware of all the facts mentioned in the contempt order. Buck also contends
that the record is not conducive to determining whether his sentence was justifiable by appropriate
sentencing factors or whether he proximately caused an injury to anybody in the course of fleeing
the courtroom.
¶ 36 Responding to these arguments, the State reiterates its position that the trial court
properly held Buck in direct criminal contempt based on conduct the court witnessed. The State
also notes that in imposing a sentence, a court is not required to outline all the factors it considered.
In the State’s view, the court properly took into account that Buck’s conduct injured people in the
courtroom, as (1) the court observed this event and (2) Buck expressed his apologies to whomever
he injured. “[I]nsofar as [Buck] raises a sentencing argument,” the State further maintains that the
six-month jail sentence was not an abuse of discretion.
¶ 37 As this court explained in Betts, 200 Ill. App. 3d at 49:
“In direct criminal contempt proceedings in which a judge has personal
knowledge of all of the facts establishing contemptuous conduct, no formal charge
is filed and no plea, issue or trial is required. Moreover, [the presentation of]
- 13 - evidence is unnecessary ***. [Citation.] Because the respondent is entitled to
appeal a direct contempt conviction, the record made in the trial court must,
however, be sufficient to permit a reviewing court to determine whether the trial
court had jurisdiction to enter the contempt order. Thus, the facts supporting the
finding of contempt must be fully set forth in the contempt order [citation] or must
appear in the transcript of the proceedings at which the contempt finding was
made.” (Internal quotation marks omitted.)
In evaluating whether a contempt order is conducive to appellate review, we may consider both
the written order and any oral findings. See People v. Wilson, 35 Ill. App. 3d 86, 88 (1975)
(“[W]here there is a complete report of proceedings which includes an oral statement of the facts
by the court, *** the report of proceedings as well as the order of the trial court will be considered
on review to determine the propriety of the order of contempt.”).
¶ 38 Here, the trial court made oral findings and entered a written contempt order. For
the same reasons explained in the preceding section, we reject Buck’s alternative argument that
the contempt ruling is not conducive to appellate review. To reiterate, the record reflects that the
court held Buck in direct criminal contempt for conduct that the court personally observed, and
there is no basis to speculate that the court improperly punished Buck for conduct that the court
learned about from third parties. The behavior that the court witnessed was contemptuous and
deserving of a six-month jail sentence. We discern no impediment to our review.
¶ 39 Buck relies heavily on Le Mirage to argue that the trial court here should have
provided more details about the injuries in the courtroom to allow for an evaluation of (1) whether
Buck’s conduct proximately caused the injuries and (2) whether the court considered an improper
sentencing factor. To that end, Buck asserts that it is unknown whether he injured people in the
- 14 - courtroom by pushing them out of the way or whether a police officer caused the injuries by firing
a gun or pepper spray into the crowd.
¶ 40 Le Mirage is an indirect criminal contempt case that did not present any issue as to
whether the challenged order was conducive to appellate review. In that case, a court ordered the
owners of a nightclub to vacate the second floor of a building due to code violations. Le Mirage,
2013 IL App (1st) 093547, ¶ 1. The owners continued to operate the nightclub on the second floor
despite the order. Le Mirage, 2013 IL App (1st) 093547, ¶ 1. One night, a fight broke out in the
nightclub, and security guards responded by using pepper spray. Le Mirage, 2013 IL App (1st)
093547, ¶ 1. This caused patrons to panic, and 21 people were crushed to death. Le Mirage, 2013
IL App (1st) 093547, ¶ 1. The City of Chicago then filed a petition to adjudicate the owners of the
nightclub in indirect criminal contempt for violating the order to vacate the second floor of the
building. Le Mirage, 2013 IL App (1st) 093547, ¶ 11. At the jury trial on those charges, the court
barred evidence of the tragedy because such evidence was unduly prejudicial. Le Mirage, 2013 IL
App (1st) 093547, ¶ 39. The jury found the owners guilty of indirect criminal contempt. Le Mirage,
2013 IL App (1st) 093547, ¶ 38. The court allowed the City of Chicago to argue at sentencing that
the tragedy was an aggravating factor, and the court sentenced the owners to two years in prison.
Le Mirage, 2013 IL App (1st) 093547, ¶¶ 39, 43. One of the issues on appeal was whether the
court improperly considered the tragedy as an aggravating sentencing factor. Le Mirage, 2013 IL
App (1st) 093547, ¶ 116. The appellate court determined that the owners’ conduct was not a
proximate cause of the tragedy, as the deaths were unrelated to the structural flaws that had
prompted the order to vacate the second floor of the building. Le Mirage, 2013 IL App (1st)
093547, ¶¶ 120-21. Thus, evidence of the tragedy was “not relevant to establishing the
seriousness” of the owners’ conduct or evaluating their rehabilitative potential. Le Mirage, 2013
- 15 - IL App (1st) 093547, ¶ 135. The matter needed to be remanded for resentencing because the
appellate court could not ascertain how much weight the trial court placed on that improper factor.
Le Mirage, 2013 IL App (1st) 093547, ¶ 142.
¶ 41 Buck’s reliance on Le Mirage in suggesting that there may be a genuine doubt as
to proximate causation here is unpersuasive. The trial court said that Buck “fled this courtroom[,]
injuring persons in the courtroom.” In his statement in allocution, Buck apologized “to the Court
and to whoever I injured in that moment.” Based on the record, the notion that the referenced
injuries might have been proximately caused by some intervening event that was completely
unforeseeable to Buck when he chose to flee the courtroom seems fanciful.
¶ 42 Buck maintains that the trial court should have included additional details as to how
the injuries occurred and made additional findings shedding light on why it decided to impose a
six-month jail sentence. However, the specific question for our consideration is whether the court’s
oral findings and written contempt order are bereft of substance and preclude meaningful appellate
review. Under the circumstances, the judgment is indeed conducive to appellate review.
¶ 43 III. CONCLUSION
¶ 44 For the reasons stated, we affirm the trial court’s judgment.
¶ 45 Affirmed.
- 16 -