People v. Colleran

2024 IL App (2d) 230604-U
CourtAppellate Court of Illinois
DecidedMarch 21, 2024
Docket2-23-0604
StatusUnpublished

This text of 2024 IL App (2d) 230604-U (People v. Colleran) 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
People v. Colleran, 2024 IL App (2d) 230604-U (Ill. Ct. App. 2024).

Opinion

2024 IL App (2d) 230604-U No. 2-23-0604 Order filed March 21, 2024

NOTICE: This order was filed under Supreme Court Rule 23(b) and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

SECOND DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE ) Appeal from the Circuit Court OF ILLINOIS, ) of McHenry County. ) Plaintiff-Appellant, ) ) v. ) Nos. 23-CF-1138 ) 23-DV-462 ) JASON S. COLLERAN, ) Honorable ) Jeffrey L. Hirsch, Defendant-Appellee. ) Judge, Presiding.

JUSTICE MULLEN delivered the judgment of the court. Presiding Justice McLaren and Justice Jorgensen concurred in the judgment.

ORDER

¶1 Held: The order of the trial court denying the State’s petition for detention is not against the manifest weight of the evidence, but the trial court erred in prohibiting the State from arguing for conditions of release not contained in its written detention motion.

¶2 I. INTRODUCTION

¶3 The State appeals an order of the circuit court of McHenry County denying its motion to

detain defendant, Jason S. Colleran, in accordance with section 110-6.1 of the Code of Criminal

Procedure of 1963 (Code) (725 ILCS 5/110-6.1 (West 2022)). For the reasons that follow, we

affirm and remand, with directions. 2024 IL App (2d) 230604-U

¶4 II. BACKGROUND

¶5 On December 8, 2023, defendant was arrested and charged with two counts of domestic

battery (720 ILCS 5/12-3.2(a)(1), (a)(2) (West 2022)), which were both class 4 felonies based on

defendant’s prior convictions (see 720 ILCS 5/12-3.2(b) (West 2022)). The State also filed two

misdemeanor counts based on the same conduct, but absent the allegation of a previous conviction.

The victim is defendant’s 19-year-old daughter. The State filed a petition to detain defendant on

that day as well.

¶6 A hearing was held on the State’s petition. In support, the State proffered, orally, the

following:

“With regard to the probable cause statement, the State would read as follows. That

without legal justification, the Defendant grabbed and pushed the victim to the floor on a

public roadway causing injury. As a victim’s statement, the State would proffer the

Defendant has been diagnosed with bipolar [disorder]. The victim believes he takes

medication. The victim states that the Defendant is a very violent person in general.”

The State continued, “With regard to the DVRA” (Domestic Violence Risk Assessment), the victim

stated that defendant “consumes alcohol in large amounts as well as cannabis,” “is an alcoholic,”

and “has bipolar disorder that he has not been taking his medication for.” It also indicated that, at

the crime scene, defendant was angry, indifferent, uncooperative, and aggressive. It then outlined

defendant’s criminal history, which includes a ten-year sentence to the Illinois Department of

Corrections (IDOC) for residential burglary in 2017, concurrent with 15 months in the IDOC for

aggravated DUI. The State also apprised the court that, in 2016, defendant was sentenced to 15

months in the IDOC for aggravated DUI and driving while his license was suspended or revoked.

Defendant was sentenced to 180 days in jail and 24 months of probation for possession of a

2 2024 IL App (2d) 230604-U

controlled substance in 2015; as well as other earlier offenses. The Probation and Court Services

Report indicates defendant had a prior conviction for domestic battery. The State argued that

defendant’s “prior criminal history which is indicative of violent, abusive, and assaultive

behavior,” along with the identity of the victim (who lived with defendant), “the nature of the

threat,” and defendant’s substance abuse and untreated mental health issues rendered him a threat

to the safety of the victim and others.

¶7 The trial court then inquired, “What other evidence do you have that he is not treating for

mental health issues?” The State indicated that this proposition was based on “the statements of

his daughter.” The State did not know how old defendant’s daughter was.

¶8 Defense counsel asked that defendant be released “with standard conditions, as well as a

short stay away in lieu of a permanent no contact order.” He stated defendant’s previous domestic

violence conviction happened over seven years ago. Further, all other violent offenses occurred

when defendant was a juvenile. It noted the charged offense was based upon “a push” and that it

did not involve weapons. The victim suffered a scraped knee that did not require medical attention.

¶9 The trial court then asked the State whether the DVRA used by pretrial services was

“geared towards intimate partner violence as opposed to a parent against what you suspect is an

adult child.” The State replied, “I do not believe it is for intimate partners.” The trial court then

pointed out that it uses the term “partner” repeatedly. We note that the DVRA has a section entitled

“Victim Interview” and asks the root question, “Has your partner (the offender) ever ***” and

there follows nine check-box-questions about the nature of any previous abuse. The document

indicates that defendant threw the victim to the ground on a roadway, where she scraped her knee.

Defendant had previously threatened to kill the victim. He did not have access to a weapon. The

3 2024 IL App (2d) 230604-U

victim responded affirmatively to the question asking whether “the violence has been getting more

severe/frequent.” It also stated that the victim did not feel that she was in danger.

¶ 10 The State reiterated that the victim reported that defendant had substance abuse and

untreated mental health issues. The trial court then stated:

“There is no indication how she knows that. That’s why I asked you what other

evidence you might have. There is evidence that he is drinking on this occasion, and he

appears to be intoxicated. And there is [sic] old convictions for DUIs. But I don’t get the

point of what you are arguing about his mental health disorder if the only evidence you

have of that is a child’s statement, who apparently moved in with him in August, according

to this. That’s why I was wondering if there is any independent basis why you think this is

a relevant factor that the victim says he has a condition, and the victim says he is not taking

medication. But I don’t know how she knows that.”

The State then replied that it believed this information was relevant and the trial court could afford

it whatever weight it deemed appropriated, to which the trial court replied, “Like zero.” It

continued:

“You know you say that all the time, but you come to these, you file petitions, and you

have no other evidence other than what the police say. It is really surprising because there

are serious cases here, and all you do is read to me documents that are in a file.”

¶ 11 The State then requested that, if the trial court determined that defendant was not

detainable, the court impose various conditions, including: that defendant surrender and refrain

from possessing any weapons; that he complete a substance abuse evaluation; that he complete

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Bluebook (online)
2024 IL App (2d) 230604-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-colleran-illappct-2024.