People v. Post

2025 IL App (4th) 241527-U
CourtAppellate Court of Illinois
DecidedMarch 13, 2025
Docket4-24-1527
StatusUnpublished
Cited by1 cases

This text of 2025 IL App (4th) 241527-U (People v. Post) 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. Post, 2025 IL App (4th) 241527-U (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (4th) 241527-U This Order was filed under FILED Supreme Court Rule 23 and is March 13, 2025 not precedent except in the NO. 4-24-1527 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. ) Fulton County JESSE POST, ) No. 23CF235 Defendant-Appellant. ) ) Honorable ) Thomas B. Ewing, ) Judge Presiding.

JUSTICE GRISCHOW delivered the judgment of the court. Justices Knecht and DeArmond concurred in the judgment.

ORDER

¶1 Held: The appellate court affirmed the trial court’s order denying defendant pretrial release, finding (1) no error when the trial court considered hearsay evidence during the detention hearing and (2) the State proved by clear and convincing evidence there was no less restrictive means of protecting the victims or the community from the threat posed by defendant; therefore, the decision to deny defendant pretrial release was not against the manifest weight of the evidence.

¶2 Defendant, Jesse Post, appeals the trial court’s order, entered November 26, 2024,

denying his pretrial release pursuant to article 110 of the Code of Criminal Procedure of 1963

(Code) (725 ILCS 5/110-1 et seq. (West 2022)), hereinafter as amended by Public Act 101-652,

§ 10-255 (eff. Jan. 1, 2023), commonly known as the Pretrial Fairness Act (Act). See Pub. Act

102-1104, § 70 (eff. Jan. 1, 2023) (amending various provisions of the Act); Rowe v. Raoul, 2023

IL 129248, ¶ 52 (setting the Act’s effective date as September 18, 2023). In accordance with

Illinois Supreme Court Rule 604(h)(7) (eff. Apr. 15, 2024), defendant relies on his motion for relief filed in the trial court as his argument on appeal. In his motion for relief, defendant argues

the court erred in considering certain hearsay evidence regarding his dangerousness and the

court’s decision to deny him pretrial release was against the manifest weight of the evidence

because the State failed to prove there is no less restrictive means of protecting the community

from the threat he may pose. For the following reasons, we affirm.

¶3 I. BACKGROUND

¶4 On November 7, 2023, defendant was charged by information with three counts

of predatory criminal sexual assault of a child (720 ILCS 5/11-1.40(a)(1) (West 2020)).

According to the information, from January 1, 2020, through May 28, 2020, defendant, who was

over 17 years of age, committed specific acts of sexual contact with C.W., F.W., and E.W., who

were all under 13 years of age at the time, for the purpose of his sexual gratification or arousal. A

warrant was issued on November 7, 2023, ordering defendant to be arrested and held for a

hearing without pretrial release. The warrant further ordered that he refrain from contact or

communication with the alleged victims. Defendant was arrested on May 24, 2024.

¶5 On May 28, 2024, the State filed a verified petition to deny defendant pretrial

release, alleging he was charged with a sex offense enumerated in the Code and his pretrial

release posed a real and present threat to the safety of any person or persons or the community

based on the specific, articulable facts of the case. See 725 ILCS 5/110-6.1(a)(5) (West 2022). A

hearing was held on the petition that same day, after which the trial court denied defendant

pretrial release. Defendant’s motion for relief pursuant to Rule 604(h)(2) was denied, and he

filed a timely appeal. Ill. S. Ct. R. 604(h)(2) (eff. Apr. 15, 2024).

¶6 On appeal, this court determined the trial court failed to make a record adequate

to allow a meaningful review of its decision to deny defendant pretrial release. Therefore, we

-2- vacated the order denying defendant’s pretrial release and remanded with directions for the trial

court to promptly set a new detention hearing, at which the State could present evidence and the

court could make express findings, based on defendant’s individual circumstances, as to whether

any condition or combination of conditions would allow for his pretrial release. People v. Post,

2024 IL App (4th) 241002-U, ¶ 29 (DeArmond, J., dissenting).

¶7 A. New Pretrial Detention Hearing on Remand

¶8 After the case was remanded, the trial court held a new detention hearing on

November 13, 2024. When discussing with the parties how to proceed, the court stated, “I think

it’s important to reconsider that evidence [from the original hearing], if there is additional

evidence also to present that, so that we can have a full understanding of the circumstances that

apply here.” Because the court expressly stated it had the transcripts of the original detention

hearing and was familiar with the proffers made at that time, we incorporate by reference our

summary of the facts in our prior decision in this case. Id. ¶¶ 4-11.

¶9 1. The State’s Evidence

¶ 10 a. Proffer of Sheriff Jonathon Webb’s Testimony

¶ 11 The State proffered Jonathon Webb, who was an investigator with the Fulton

County Sheriff’s Office (and is now the Fulton County sheriff), would testify to the following

facts about a prior, unrelated investigation regarding defendant. Sheriff Webb interviewed

defendant on September 22, 2017, regarding a complaint made by defendant’s four-year-old

daughter, L.G. (born October 2012). That same day, Sheriff Webb had been present during a

forensic interview of L.G. with the Children’s Advocacy Centers of Illinois (CAC). The

interview was conducted by Phyllis Todd of the Fulton-Mason Crisis Service. Sheriff Webb

would testify that L.G. said defendant “licked her butt on at least one occasion.” The State

-3- explained L.G. told Todd, “ ‘One time Daddy—who is the defendant in this case—took me in

the woods’ ” to retrieve a frisbee because “her father had thrown [it] too far.” L.G. said,

“ ‘[Defendant] peed with me’ ” and then “ ‘he licked my butt.’ ” L.G. identified body parts on a

diagram during the interview, identifying the “buttocks as the butt” and “referred to both the

vagina and penis as dooder.” Defendant denied these allegations during his interview with

Sheriff Webb.

¶ 12 b. Proffer of Officer Ryan McCabe’s Testimony

¶ 13 The State proffered Officer Ryan McCabe of the Canton Police Department

would testify to the following facts regarding the allegations in this case.

¶ 14 Officer McCabe spoke with Breitanyia L., the mother of the three victims, about a

criminal sexual assault complaint made approximately three years ago. Officer McCabe would

testify Breitanyia reported that E.W., her seven-year-old son (born March 2016), made

“statements regarding a sexual assault that happened to him in Canton.” Breitanyia initially

reported the incident to the Peoria Police Department and was then told to contact the Canton

Police Department. Breitanyia told Officer McCabe the incident was investigated, but E.W. was

not interviewed because he was “too young at the time.” The other two victims, F.W. (born

February 2013) and C.W. (born June 2014), were interviewed in 2020. In the original proffer

regarding this initial investigation, the State explained the two older girls did not make any

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Related

People v. Post
2025 IL App (4th) 250598 (Appellate Court of Illinois, 2025)

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Bluebook (online)
2025 IL App (4th) 241527-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-post-illappct-2025.