People v. Odehnal

4 Citing cases

  1. People v. Andino-Acosta

    2024 Ill. App. 2d 230463 (Ill. App. Ct. 2024)   Cited 37 times
    In Andino-Acosta, the court considered Justice Boie's dissent in People v. Odehnal, 2024 IL App (5th) 230877-U, ¶ 18, where in denying pretrial release, the circuit court made detailed, fact-specific findings as to why pretrial release was denied. Andino-Acosta, 2024 IL App (2d) 230463, ¶ 16.

    ¶ 16 People v. Odehnal, 2024 IL App (5th) 230877-U, reversed a detention order based, at least in part, upon deficiencies in the written order. However, Justice Boie, in a well-reasoned dissent, described "extremely detailed, fact specific findings" made orally by the trial court and argued that "the trial court's written order, taken in conjunction with the specific findings stated on the record, was sufficient to properly comply with section 110-6.1(h)(1)."

  2. People v. Castillo

    2024 Ill. App. 232315 (Ill. App. Ct. 2024)

    In People v. Andino-Acosta, 2024 IL App (2d) 230463, ¶ 19, the Second District held that an explicit and individualized oral ruling may satisfy the statute. In Andino-Acosta, the court considered Justice Boie's dissent in People v. Odehnal, 2024 IL App (5th) 230877-U, ¶ 18, where in denying pretrial release, the circuit court made detailed, fact-specific findings as to why pretrial release was denied. Andino-Acosta, 2024 IL App (2d) 230463, ¶ 16.

  3. People v. Thomas

    2024 Ill. App. 4th 240248 (Ill. App. Ct. 2024)   Cited 8 times

    ¶ 21 On defendant's first point, we note that all appellate court districts have now recognized that a circuit court's oral pronouncements can be considered in conjunction with its written explanation in assessing the court's compliance with section 110-6.1(h)(1). See, e.g., People v. Davis, 2023 IL App (1st) 231856, ¶ 34; People v. Andino-Acosta, 2024 IL App (2d) 230463, ¶ 15; People v. Hodge, 2024 IL App (3d) 230543, ¶¶ 11-12; McKenzie, 2024 IL App (4th) 231063-U, ¶ 17; People v. Odehnal, 2024 IL App (5th) 230877-U, ¶ 11. Indeed, given that the point of requiring a written finding is to give notice of the reasons for the court's findings for appellate review, the same purpose is served when the court's findings are stated orally.

  4. People v. Castillo

    2024 Ill. App. 232315 (Ill. App. Ct. 2024)

    In People v. Andino-Acosta, 2024 IL App (2d) 230463, ¶ 19, the Second District held that an explicit and individualized oral ruling may satisfy the statute. In Andino-Acosta, the court considered Justice Boie's dissent in People v. Odehnal, 2024 IL App (5th) 230877-U, ¶ 18, where in denying pretrial release, the circuit court made detailed, fact-specific findings as to why pretrial release was denied. In his dissent, Justice Boie referred to In re Madison H., 215 Ill.2d 364 (2002), where the Illinois Supreme Court considered a similar statute that required the circuit court to make a written finding for determining whether a parent is unfit to raise a child.