People v. Ladd

• Court: Appellate Court of Illinois
• Decided: May 29, 2026
• Docket: 5-26-0187
• Status: Unpublished

Opinion

NOTICE 2026 IL App (5th) 260187-U NOTICE Decision filed 05/29/26. The This order was filed under text of this decision may be NO. 5-26-0187 Supreme Court Rule 23 and is changed or corrected prior to not precedent except in the the filing of a Petition for IN THE limited circumstances allowed Rehearing or the disposition of under Rule 23(e)(1). the same. APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Jefferson County. ) v. ) No. 26-CF-27 ) PERICE L. LADD, ) Honorable ) Denton W. Aud, Defendant-Appellant. ) Judge, presiding. ______________________________________________________________________________

JUSTICE CLARKE delivered the judgment of the court. Justices McHaney and Vaughan concurred in the judgment.

ORDER

¶1 Held: The trial court’s orders granting the State’s verified petition to deny pretrial release and denying the defendant’s motion for relief are affirmed.

¶2 The defendant, Perice L. Ladd, appeals from the Jefferson County trial court’s January 16,

2026, order granting the State’s petition to deny pretrial release, as well as the court’s March 4,

2026, order denying his motion for relief and immediate release. For the following reasons, we

affirm.

¶3 I. BACKGROUND

¶4 On January 14, 2026, the defendant was charged with aggravated domestic battery, a Class

2 felony. 720 ILCS 5/12-3.3(a) (West 2024). The charge alleged that the defendant caused great

bodily harm to Leslie Courtney, his girlfriend, in that he struck Courtney’s face with his fists,

1 causing her to suffer a broken nose. The defendant was later indicted by a grand jury for the same

offense on January 22, 2026.

¶5 The State filed a verified petition to deny the defendant pretrial release on January 15,

2026, alleging that the defendant committed a detainable offense, being aggravated domestic

battery, and his pretrial release posed a real and present threat to the safety of any person or persons

or the community. 725 ILCS 5/110-6.1(a)(4) (West 2024).

¶6 The matter proceeded to a hearing on January 16, 2026. The State provided its factual basis

by proffer, based upon the Mt. Vernon Police Department’s (MVPD) narrative, as well as the

pretrial investigation report. The State asserted that Officer Karch of the MVPD would testify that

at approximately 12:53 a.m. on December 25, 2025, he responded to a report involving a female

trespassing at a residence on Apple Avenue. Upon arrival, he made contact with Leslie Courtney,

who was sitting on a step of the residence with visible injuries. Officer Karch noted a “possible

broken nose, multiple lumps on her head,” and a large amount of blood present on her face and

shirt. Emergency services were dispatched to the scene. Officer Karch took photographs of

Courtney and her injuries, which were admitted into evidence and included in the record on appeal.

The photographs show Courtney with visible injuries to her face as described, as well as blood on

her face, in her mouth, and on her clothing.

¶7 The State continued its proffer, stating that Courtney provided an account to Officer Karch.

She stated that she had been beaten by the defendant while inside a silver 2018 Ford Taurus.

Courtney stated that she jumped out of the vehicle to escape the battery and ran to a nearby house

for help. She reported that her injuries were from being struck by the defendant, but did not recall

if the defendant used anything other than his fists to hit her. Courtney said that the battery occurred

throughout Mt. Vernon until she eventually jumped out of the vehicle. She provided officers with

2 possible locations where the defendant might be and informed them that the defendant was subject

to mandatory supervised release (MSR). Courtney stated that she wished to pursue charges against

the defendant. Courtney was taken to Good Samaritan Hospital, where doctors had to heavily

sedate her due to the injuries.

¶8 Approximately 12 hours after the initial encounter with Courtney, Officer Ackley of the

MVPD received a phone call from the defendant. He informed Officer Ackley that he was the

victim of the incident and wanted to complete a report for himself. The defendant said that he and

Courtney were in a prior relationship, and reengaged in the relationship after he was released from

prison. The previous evening, the defendant stated that he picked Courtney up and drove to locate

a liquor store before going to a friend’s house on Apple Avenue. The defendant stated that he,

Courtney, and his friend were sitting on the porch, drinking, when he received a notification on

his phone, and Courtney “began yelling at him because she thought he was cheating on her.” The

defendant then said he was hit over the head with a liquor bottle over his left eye. He was hit again

and then blacked out. The defendant told officers he was unconscious from that point until an hour

before he contacted the police. He stated he wanted to press charges and that he was going to the

hospital. Officers asked the defendant to bring his medical records from the hospital, to which he

informed officers that his lawyer would bring them. Officers also advised the defendant that it

would be best for him to provide a statement in person so his visible injuries could be confirmed,

as well as his identity. The defendant stated that his lawyer would do that and provide a statement

as well.

¶9 Officer Jackson of the MVPD received a phone call on December 26, 2025, from the

defendant, stating that he was hit first by Courtney. Further, the parties were not in a romantic

relationship, but only a sexual relationship. He emailed two photos showing injuries that he

3 sustained at the hands of Courtney, and stated that he would come to the police department along

with his attorney.

¶ 10 At approximately 4 p.m. on December 26, 2025, Jackson obtained a formal recorded

statement from Courtney. She stated that she had been in a relationship with the defendant since

October 2025, and that they “reconnected for a dating relationship which she confirmed was sexual

in nature.” Courtney stated that the defendant had a history of violence towards her, including a

few weeks prior, when he “choked her to the point where she could not breathe and had beaten

her.” She had photographic evidence of her injuries, which the defendant later deleted from her

phone. She said that she did not report the prior incident because the defendant threatened to kill

her and her children if she did.

¶ 11 Courtney told Officer Jackson of the events of December 24, 2025, leading up to the

offense. The defendant picked Courtney up, then drove to Mt. Vernon, and while parked in a

driveway, the defendant began punching Courtney. When Courtney attempted to leave the vehicle,

he hit her again, forced her to stay, then threatened to take her to Rend Lake to kill her. When the

defendant exited the vehicle, Courtney saw her opportunity to escape and ran to a nearby house to

ask the occupants to call the police on her behalf. She reported that the defendant consumed a

“significant amount of alcohol.”

¶ 12 Courtney told officers that there was a bottle of tequila in the defendant’s vehicle, and she

denied hitting the defendant with any objects. Courtney described several personal items left in

the vehicle, including a purse, coat, phone, lanyard, and her wallet. She expressed fear for her

safety and said that the defendant was determined to harm her.

¶ 13 Pursuant to a search warrant, Detective Kane of the MVPD processed the silver Ford

Taurus that was linked to the defendant. The personal effects described by Courtney were located

4 within the vehicle and provided to her. There was a large amount of what appeared to be blood in

the passenger seat, on the console, and partially in the driver’s seat. Swabs were taken from the

vehicle.

¶ 14 Defense counsel then proceeded by proffer. The defendant was 42 years old and had lived

in Jefferson County for most of his life with significant family ties to the area. He was employed

at the time of his arrest and was not on probation, bond, or pretrial release. Defense counsel stated

that the defendant was claiming self-defense because Courtney hit him in the head with a bottle.

The defendant sent pictures to Officer Jackson of a faint red mark above his left eye from the bottle

injury.

¶ 15 The State then proceeded to argument, asking that the defendant be denied release pending

trial. The State asserted that the defendant committed the qualifying offense of aggravated

domestic battery. The State said that the crime was committed against Courtney and she “suffered

grievous injuries,” which were photographed shortly after the offense. The State asserted that the

defendant’s vehicle was located with what appeared to be an excess amount of blood in the

passenger seat and center console, but the defendant was not with his vehicle, which was

“incredibly suspicious given the fact pattern and given the narratives that we have at this time.”

The defendant contacted the MVPD approximately 12 hours after Courtney did, but he declined

to come to the police department to show his injuries or provide his medical record. The State

argued that the defendant “appeared to not be fully forthcoming in his level of cooperation as it

would relate to these potential charges against” Courtney.

¶ 16 The State continued, arguing that the defendant had an extensive criminal history,

including felony and misdemeanor domestic battery, felony aggravated domestic battery, and

5 felony residential arson, for which he was sentenced to 15 years in the Illinois Department of

Corrections. He was subject to MSR at the time of the offense.

¶ 17 Courtney “clearly and unequivocally stated that she was pursuing charges” and wanted to

obtain an order of protection due to her fears of the defendant. He told Courtney he was going to

kill her, and the State argued, “There is a[n] absolute public safety and personal safety argument

to be made on behalf of [Courtney] as it relates to her potential for more bodily harm to befall her”

as well as the psychological harm that would come from the defendant’s release.

¶ 18 The State argued that no condition or combination of conditions would ensure that the

defendant would not violate any further laws or appear for court dates, as he was already under

mandatory supervision when the offense occurred. The State asked for the defendant to be

detained.

¶ 19 Defense counsel then argued that the defendant was willing to submit to any conditions of

release, such as electronic monitoring and home confinement. Courtney lived in a different county

from the defendant, and the defendant asserted that he acted in self-defense. Defense counsel

argued that the State failed to prove that the defendant posed a danger to any person, persons, or

the community by clear and convincing evidence, and requested the defendant’s release on home

confinement with electronic monitoring.

¶ 20 The trial court stated that it considered the pretrial investigation report, evidence presented

by proffer, and arguments of counsel. The trial court found that the State proved by clear and

convincing evidence that the proof was evident or presumption great that the defendant committed

a qualifying offense, being aggravated domestic battery. The trial court addressed the photos of

Courtney’s “severe injuries,” the defendant’s claim of self-defense, and the blood located within

6 the vehicle. The court found that Courtney’s injuries qualified as great bodily harm as well, and

that the State met its burden of proving that the defendant committed a detainable offense.

¶ 21 As to whether the defendant posed a real and present threat, the trial court said that the

defendant posed a threat to Courtney, as well as the community. The trial court considered the

parties’ actions, including Courtney’s reporting the offense to law enforcement and then seeking

medical treatment, but the defendant waited several hours, did not come to make a statement, and

said that his lawyer would come to the police department on his behalf. The trial court found that

the State met its burden.

¶ 22 As to conditions, the trial court said that the defendant’s criminal history was severe, and

he was on MSR, which required that the defendant comply with the conditions of his release. His

history included residential arson, domestic battery, aggravated domestic battery, drug delivery,

and misdemeanor domestic battery. The trial court described it as “a constant escalation.” The trial

court said, “It’s hard to imagine that there’s any condition, [Defendant], that would mitigate the

risk that you pose to any person, or persons, or the community.” The trial court granted the State’s

petition to detain. The trial court entered an order on the same date, including that less restrictive

conditions would not assure the safety of any person or the community due to the nature of the

case, the extent of Courtney’s injuries, the defendant’s criminal history, and his MSR status.

¶ 23 The defendant’s counsel filed a motion for relief and immediate release on January 20,

2026. The motion alleged that the State failed to meet its burden of proving, by clear and

convincing evidence, that the proof was evident or the presumption great that the defendant

committed a qualifying offense, that he posed a real and present threat to the safety of any person

or persons or the community, and that no condition or combination of conditions could mitigate

the real and present threat. The motion argued that the trial court failed to fully consider the

7 defendant’s ties to the community, willingness to abide by any terms of pretrial release,

employment opportunities, claim of self-defense, and that no weapon was used in the commission

of the alleged offense.

¶ 24 The matter proceeded to a hearing on March 4, 2026. Defense counsel reiterated the factual

proffer provided during the initial hearing and argued that the trial court failed to consider the

factors listed in the motion for relief. Defense counsel then presented a written statement from the

defendant, which provided a legal argument that “the State failed to prove a qualifying relationship

for domestic battery.” Defense counsel asked for the defendant’s release with home confinement

and electronic monitoring.

¶ 25 The State said that its posture was “unchanged” from the initial detention hearing. The

State asked the trial court to consider the pretrial investigation report, the photographs of

Courtney’s injuries that were admitted as exhibits, and the factual proffer. The defendant had an

extensive criminal history and was on MSR at the time of the offense. The State argued that his

MSR status “was insufficient to deter him from further criminal behavior” and took the position

that no less restrictive means were available to ensure the defendant would not violate the law

pending trial. The State asked for the defendant to be detained for the safety of Courtney.

¶ 26 The trial court stated that it considered the motion for relief, proffers and arguments from

the initial hearing, the written statement from the defendant, and the argument from the State. The

trial court denied the defendant’s motion for relief. The defendant appealed.

¶ 27 II. ANALYSIS

¶ 28 On appeal, the Office of the State Appellate Defender (OSAD) was appointed as appellate

counsel. The defendant was permitted, but not required, to file a memorandum on appeal. OSAD

never filed a memorandum or a notice in lieu of a memorandum pursuant to Rule 604(h)(7). “Issues

8 raised in the motion for relief are before the appellate court regardless of whether the optional

memorandum is filed.” Ill. S. Ct. R. 604(h)(7) (eff. Apr. 15, 2024). Therefore, our review is limited

to the issues raised in the motion for relief.

¶ 29 The defendant’s motion for relief states the following:

“7. The Court erred in granting the State’s Petition to Deny Pre-Trial Release at [the initial

detention hearing], in that the State failed to meet its burden of proving by clear and

convincing evidence any of the above in that:

a. The Court failed to fully consider Defendant’s ties to the community.

b. The Court failed to fully consider Defendant’s willingness to abide by any

terms of pretrial release.

c. The Court failed to fully consider Defendant’s employment opportunities.

d. The Court failed to fully consider Defendant’s claim of self-defense.

e. No weapon was used in the commission of the allege[d] offense.”

¶ 30 The State argues on appeal that the defendant has waived all issues on appeal for failure to

provide citations to the record in his motion for relief. While we do not agree that the defendant

waived all argument due to the failure to cite to the record on appeal, we do find that he has waived

all argument on appeal for failure to provide sufficient arguments with citations to any relevant

authorities. Ill. S. Ct. R. 604(h)(7) (eff. Apr. 15, 2024).

¶ 31 “Whether made in the motion for relief alone or as supplemented by the memorandum, the

form of the appellant’s arguments must contain sufficient detail to enable meaningful appellate

review, including the contentions of the appellant and the reasons therefore and citations of the

record and any relevant authorities.” Id. A party may not simply “dump the burden of argument

and research” on the reviewing court; rather, a reviewing court is “entitled to have the issues clearly

9 defined and to be cited pertinent authority.” (Emphasis omitted.) People ex rel. Illinois Department

of Labor v. E.R.H. Enterprises, Inc., 2013 IL 115106, ¶ 56. A reviewing court “cannot be expected

to formulate an argument for defendant out of whole cloth.” People v. Inman, 2023 IL App (4th)

230864, ¶ 13.

¶ 32 “[D]efendants must endeavor to present a more complete analysis of the issues in their

motions for relief or, as the rule allows, file a supplemental memorandum in support of the appeal

rather than relying on the appellate court to do the work for them.” People v. Post, 2025 IL App

(4th) 250598, ¶ 23. Failure to comply with Rule 604(h)(7)’s requirement of presenting arguments

with sufficient detail to enable meaningful appellate review constitutes waiver of the issue on

appeal. Ill. S. Ct. R. 604(h)(7), (2) (eff. Apr. 15, 2024). Unlike forfeiture, which is a limitation on

the parties, waiver is a limitation on this court and precludes review. People v. Nettles, 2024 IL

App (4th) 240962, ¶ 29 (citing United States v. Flores, 929 F.3d 443, 447 (7th Cir. 2019) (“We

reviewed forfeited arguments for plain error, whereas waiver extinguishes error and precludes

appellate review.”)).

¶ 33 In the present case, the defendant’s motion for relief asserts that the trial court erred in

granting the State’s petition to deny his pretrial release due to the State’s failure to meet its burden

of proof for “any of the above,” which includes the elements of the statute: that the proof is evident

or presumption great that the defendant committed a qualifying offense, that he poses a real and

present threat to the safety of any person or the community, and that no condition or combination

of conditions can mitigate that threat. The motion for relief serves more than one purpose. People

v. Patterson, 2025 IL App (1st) 250510, ¶ 18. Its initial purpose is to give the aggrieved party an

opportunity to draw the circuit court’s attention to any errors it may have made in the initial release

10 determination and give the court an opportunity to correct them. Id. But it also “crystalizes and

frames the issues for appeal.” Id. ¶ 19.

¶ 34 Rather than clearly arguing how the State failed to prove each element of the statute,

defendant’s counsel instead provided a list of factors the trial court “failed to fully consider.” The

arguments in the motion for relief are undeveloped. They are not applied to each element of pretrial

detention and do not explain why the factors presented outweigh the other elements the trial court

could consider in determining detention, such as the defendant’s criminal history. The motion

asserts that the trial court failed to consider the defendant’s willingness to abide by pretrial release

conditions, but does not argue how this consideration would outweigh the defendant’s history and

current status on MSR. Outside of the case law introducing the pretrial detention standard of review

applicable on appeal, the motion for relief does not provide any citations to relevant authorities

that would be pertinent to the defendant’s case.

¶ 35 These “[b]are contentions in the absence of argument or citation of authority do not merit

consideration on appeal.” Obert v. Saville, 253 Ill. App. 3d 677, 682 (1993). Reviewing courts are

entitled to have the issues clearly defined, pertinent authority cited, and cohesive arguments

presented. Id. The purpose of requiring the appellant’s memorandum or motion for relief to contain

detailed arguments is, as explained by the task force that recommended its adoption, to prohibit

just such a conclusory argument in pretrial-release appeals:

“We believe that this rule is essential to discourage the boilerplate ‘arguments’ we have

seen in the existing check-the-box notice of appeal. We remain ever mindful that, as

appellate judges, we may not serve as advocates for a party. Presentation of the appellant’s

argument in a cursory manner pressures the court to abandon the role it is ethically

obligated to play: that of a neutral arbiter.” (Emphasis added.) Ill. S. Ct. Pretrial Release

11 Appeals Task Force, Report and Recommendations 8 (2024), https://

ilcourtsaudio.blob.core.windows.net/antilles-resources/resources/628434e3-d07f-4ead

b1f6 4470d7e83bf3/Pretrial%20Release%20Appeals%20Task%20Force%20Report_

March%202024.pdf [https://perma.cc/LL5Y-R4FN].

People v. Hood, 2026 IL App (1st) 260117-U, ¶ 13.

¶ 36 The defendant does not provide any specific argument as to the elements within his motion

for relief, and it is not this court’s position to argue and advocate on his behalf as to how these

elements impact his pretrial detention. As the defendant has not provided any argument within his

motion for relief that would contain sufficient detail to enable meaningful appellate review, he has

waived all argument on appeal. Due to the defendant’s waiver, any potential error has been

extinguished. As such, the trial court’s detention order and denial of the motion for relief are

affirmed.

¶ 37 III. CONCLUSION

¶ 38 Based on the foregoing reasons, we affirm the trial court’s orders of January 16, 2026, and

March 4, 2026.

¶ 39 Affirmed.