People v. Craig

Procedural entryThis page is a short order in People v. Craig. Read the opinion of the Court — 403 Ill. App. 3d 762
Appellate Court of Illinois·Decided August 20, 2010·No. 5-08-0360 Rel·Published

Opinion

NO. 5-08-0360 N O TIC E

D ecision filed 08/20/10. T he text of IN THE this decision m ay b e changed or

corrected prior to the filing of a APPELLATE COURT OF ILLINOIS P e titio n fo r R ehearin g or th e

disposition of the sam e. FIFTH DISTRICT ________________________________________________________________________

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Petitioner-Appellee, ) Wayne County. ) v. ) No. 98-CF-135 ) CHRISTOPHER L. CRAIG, ) Honorable ) Barry L. Vaughan, Respondent-Appellant. ) Judge, presiding. ________________________________________________________________________

JUSTICE DONOVAN delivered the opinion of the court:

Respondent, Christopher L. Craig, confessed the petition to declare respondent a

sexually dangerous person filed by petitioner, the People of the State of Illinois (State), in the

circuit court of Wayne County pursuant to the Sexually Dangerous Persons Act (Act) (725

ILCS 205/0.01 et seq. (West 2006)), and he was committed to the custody of the Illinois

Department of Corrections (Department). Subsequently, respondent filed an application

showing his recovery and sought a discharge or alternatively a conditional release.

Following an evidentiary hearing, the jury found that respondent continued to be sexually

dangerous. Respondent was remanded to the custody of the Department. On appeal,

respondent contends that he was deprived of his constitutional right to due process when the

circuit court denied his motion for an independent psychiatric evaluation at the State's

expense and instructed the jury on a burden of proof that was less than beyond a reasonable

doubt.

On August 7, 1998, the State filed an information in the circuit court of Wayne

County charging respondent with one count of sexual assault and two counts of predatory

1 criminal sexual assault of a child. On October 19, 1998, the State filed a petition to declare

respondent a sexually dangerous person pursuant to the Act (725 ILCS 205/3 (West 1998)).

On October 28, 1998, the circuit court appointed two qualified psychiatrists and directed

each, independently, to evaluate respondent for purposes of determining whether he was a

sexually dangerous person pursuant to section 4 of the Act (725 ILCS 205/4 (West 1998)).

On January 25, 1999, respondent confessed the State's petition and the allegations

contained therein, waived his right to a jury trial, and consented to a court-ordered

commitment to the custody of the Department under the guardianship of the Director of

Corrections (Director). On January 25, 1999, the circuit court entered an order finding that

respondent was a sexually dangerous person, appointing the Director as respondent's

guardian, and committing respondent to the custody of the Director.

In April 2002, respondent filed a pro se "Application Showing Recovery" pursuant

to section 9 of the Act (725 ILCS 205/9 (West 2002)) in the circuit court of Wayne County.

Respondent requested that the court grant a discharge from commitment or alternatively a

conditional release from commitment. The circuit court appointed an attorney to represent

respondent. Respondent's attorney filed an amended application and a motion for the

appointment of an independent expert at the State's expense to examine respondent for the

purpose of determining whether he remained a sexually dangerous person. The court denied

respondent's motion for the appointment of an independent expert. The court ordered the

Director to cause to be prepared and to be filed a sociopsychiatric report pursuant to section

9 of the Act.

An evidentiary hearing was held on May 7, 2003. At the conclusion of the trial, the

court determined that respondent continued to suffer from a mental disorder and that

respondent had a problem controlling his behavior. The court denied respondent's amended

application showing a recovery. On appeal, a panel of this court determined that respondent

2 was not entitled to an independent expert and that the State had presented overwhelming

evidence to show that respondent continued to be a sexually dangerous person; the judgment

was affirmed. People v. Craig, 351 Ill. App. 3d 1191, 876 N.E.2d 331 (2004) (unpublished

order under Supreme Court Rule 23 (166 Ill. 2d R. 23)).

On May 9, 2005, respondent filed a pro se application for a discharge or a conditional

release and a motion for the appointment of counsel in the circuit court of Wayne County.

The circuit court granted respondent's motion for the appointment of counsel. The court

ordered the Director to have a sociopsychiatric report prepared and submitted. On April 10,

2006, respondent filed an amended application. Respondent also filed a motion seeking a

Frye hearing (Frye v. United States, 293 F. 1013 (D.C. Cir. 1923)) and the appointment of

an independent psychiatric expert at the State's expense. The court denied respondent's

requests for a Frye hearing and the appointment of an independent psychiatric expert. An

evidentiary hearing before a jury was held from December 17, 2007, through December 18,

2007. The jury found that respondent continued to be a sexually dangerous person. The

court entered a judgment on the verdict and remanded respondent to the custody of the

Director. The court denied respondent's posttrial motion seeking a judgment notwithstanding

the verdict or alternatively a new trial.

On appeal, respondent argues that he was deprived of constitutional safeguards when

the circuit court refused to appoint an independent expert at the State's expense and when the

court instructed the jury on a burden of proof that was less than beyond a reasonable doubt.

Respondent contends that the circuit court's decision to instruct the jury on a burden of proof

that was less than beyond a reasonable doubt in conjunction with its decision to deny his

motion for a psychiatric expert resulted in a deprivation of his constitutional right to due

process in the recovery proceeding because he was required to proceed to a trial without the

ability to offer any evidence to counter the Department's experts while the State was faced

3 with a lesser burden of proof.

The standard of review for determining whether an individual's constitutional rights

have been violated is de novo. Patel v. Illinois State Medical Society, 298 Ill. App. 3d 356,

370, 698 N.E.2d 588, 597 (1998). Matters of statutory construction and statutory

interpretation are also reviewed de novo. In re Detention of Kish, 395 Ill. App. 3d 546, 554,

916 N.E.2d 595, 601 (2009).

The Sexually Dangerous Persons Act provides for the involuntary civil commitment

of respondents declared sexually dangerous persons, as an alternative to criminal

prosecutions. 725 ILCS 205/2, 3 (West 2006). The Act serves both the individuals and

society, in that it offers to provide treatment for sexually dangerous persons with the goals

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

People v. Craig, (Ill. Ct. App. 2010).

People v. Craig (People v. Craig) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Addington v. Texas
441 U.S. 418 (Supreme Court, 1979)
Allen v. Illinois
478 U.S. 364 (Supreme Court, 1986)
In Re CMJ
663 N.E.2d 498 (Appellate Court of Illinois, 1996)
Modern Dairy Co. v. Department of Revenue
108 N.E.2d 8 (Illinois Supreme Court, 1952)
Patel v. Illinois State Medical Society
698 N.E.2d 588 (Appellate Court of Illinois, 1998)
People v. Burns
809 N.E.2d 107 (Illinois Supreme Court, 2004)
Bazydlo v. Volant
647 N.E.2d 273 (Illinois Supreme Court, 1995)
People v. Allen
481 N.E.2d 690 (Illinois Supreme Court, 1985)
People v. Lawton
818 N.E.2d 326 (Illinois Supreme Court, 2004)
In Re Detention of Kish
916 N.E.2d 595 (Appellate Court of Illinois, 2009)
People v. Craig
876 N.E.2d 331 (Appellate Court of Illinois, 2004)
People v. Hickman
644 N.E.2d 1147 (Illinois Supreme Court, 1994)
People v. Trainor
752 N.E.2d 1055 (Illinois Supreme Court, 2001)
The People v. Capoldi
225 N.E.2d 634 (Illinois Supreme Court, 1967)
People v. Brenda T.
818 N.E.2d 1214 (Illinois Supreme Court, 2004)
People v. Edwin Aadil J.
663 N.E.2d 498 (Appellate Court of Illinois, 1996)
Frye v. United States
293 F. 1013 (D.C. Circuit, 1923)