People v. Quib

2025 IL App (2d) 250234-U

• Court: Appellate Court of Illinois
• Decided: August 25, 2025
• Docket: 2-25-0234
• Status: Unpublished

Opinion

2025 IL App (2d) 250234-U No. 2-25-0243 Order filed August 25, 2025

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 Kane County. ) Plaintiff-Appellee, ) ) v. ) No. 25-CF-1203 ) RONI H. CHOC QUIB, ) Honorable ) Juila A. Yetter, Defendant-Appellant. ) Judge, Presiding. ______________________________________________________________________________

PRESIDING JUSTICE KENNEDY delivered the judgment of the court. Justices Jorgensen and Birkett concurred in the judgment.

ORDER

¶1 Held: Defendant forfeited his arguments on appeal from the trial court’s order denying him pretrial release where his motion for relief contained only vague assertions of error unsupported by argument or authorities. Forfeiture aside, there was sufficient evidence to support the trial court’s denial of pretrial release where defendant’s criminal history included, inter alia, recent convictions arising from incidents of domestic violence against the same victim. Affirmed.

¶2 Defendant, Roni H. Choc Quib, appeals from the denial of his pretrial release under section

110-6.1 of the Code of Criminal Procedure of 1963 (Code) (725 ILCS 5/110-6.1 (West 2024)). As

defendant did not file a memorandum, his motion for relief from pretrial detention serves as his

argument on appeal. See Ill. S. Ct. R. 604(h)(7) (eff. Apr. 15, 2024). For the following reasons, we 2025 IL App (2d) 250234-U

affirm.

¶3 I. BACKGROUND

¶4 On May 26, 2025, defendant was charged via complaint with three counts of domestic

battery (making physical contact with prior conviction) (720 ILCS 5/12-3.2(a)(2) (West 2024)),

two counts of domestic battery (causing bodily harm with prior conviction) (id. § 12-3.2(a)(1)),

and obstructing a police officer (id. § 31-1(a)(2)). The charges arise out of an incident where

defendant allegedly grabbed the arm of the victim (whom defendant had been dating for three

years), causing redness and swelling, struck the right side of her face causing redness, swelling,

and her nose to bleed, and then struck the left side of her head.

¶5 Defendant was arrested and the State filed a verified petition to deny pretrial release on

May 27, 2025, and the trial court granted the State’s petition to deny defendant pretrial release that

same day. On June 6, 2025, defendant filed a motion for relief, which was denied on June 11,

2025. Defendant timely appealed.

¶6 II. ANALYSIS

¶7 This appeal involves only the review of documentary evidence and proffer, with no live

testimony. We therefore review the denial of defendant’s pretrial release de novo. People v.

Morgan, 2025 IL 130626, ¶ 22.

¶8 All defendants shall be presumed eligible for pretrial release, and the State shall bear the

burden of proving otherwise by clear and convincing evidence. 725 ILCS 5/110-6.1(e) (West

2024). To deny a defendant’s pretrial release, the State must show (1) that the proof is evident or

the presumption great that the defendant has committed an eligible offense, and (2) the defendant

poses a real and present threat to the safety of any person or persons or the community, which (3)

no condition or combination of conditions can mitigate. Id. The trial court’s finding that no

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combination of conditions can mitigate the threat posed by a defendant must be based on the

specific articulable facts of the case. Id. § 110-6.1(e)(3).

¶9 On appeal, defendant argues that the State failed to show by clear and convincing evidence

that (1) the proof was evident or presumption great that defendant committed the charged offenses,

(2) defendant was a real and present threat to the safety of the alleged victim, and (3) no conditions

existed which could mitigate the threat posed by defendant, without any further elaboration as to

how the State’s proofs were insufficient as to any of the three elements. “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.” Ill. S. Ct. R. 604(h)(7) (eff. Apr. 15, 2024). The failure to assert a well-reasoned

argument supported by legal authorities results in forfeiture of the issue on appeal. People v.

Agnew-Downs, 404 Ill. App. 3d 218, 231 (2010).

¶ 10 Forfeiture aside, the record contains sufficient evidence to establish each of the necessary

elements of pretrial detention. The defense presented a police synopsis from defendant’s arrest in

the instant case, wherein the victim stated that defendant struck her, and the officers observed signs

of injury, including a bloody nose. Defendant was located by officers outside of the home where

they ordered him to stop and grabbed his arm, upon which defendant pulled away and attempted

to flee. The contents of the synopsis were un-rebutted although the defense proffered that he had

a part-time job, two children, and a place to live.

¶ 11 Defendant’s criminal history included two other incidents of domestic violence against the

same victim, including an incident where defendant punched the victim in the mouth knocking out

three false teeth, and an incident where defendant placed the victim in a chokehold and said, “I’m

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going to kill you I don’t care if I rot in jail.” During one of these incidents, defendant resisted arrest

and attempted to take the arresting officer’s duty weapon. Additionally, there was a domestic

violence incident which involved defendant’s roommate, in which defendant struck his roommate

and attempted to grab a knife from the kitchen cutlery drawer before being restrained. Defendant

was on either probation or conditional release from these convictions at the time of the instant

offense. Additionally, defendant’s ODARA risk assessment was one of the highest levels on the

scale, predicting a 74% likelihood of community with another assault on a female domestic partner

within five years. In short, there was sufficient evidence that defendant committed a domestic

battery and obstructed an officer, that he posed a danger to the victim and others, and that no

conditions of release would sufficiently mitigate the violent threat he posed.

¶ 12 III. CONCLUSION

¶ 13 Accordingly, we affirm the judgment of the circuit court of Kane County.

¶ 14 Affirmed.

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