Background
Jonathan Tyler Warner was initially released pending charges that included domestic battery against his girlfriend, J.B., and resisting police. His release conditions included a no-contact order with J.B. Warner later failed to appear in court.
After his arrest in September 2025, Warner was charged with aggravated domestic battery, unlawful restraint, domestic battery, interfering with a domestic-violence report, and violating pretrial-release conditions. The State alleged that, during an argument at J.B.’s home, Warner blocked her from leaving, took her phone, and placed both hands around her neck for five to six seconds, preventing her from breathing. The circuit court denied release in the new case and revoked release in the original case.
The Court’s Holding
The Illinois Appellate Court, Fourth District, affirmed. Reviewing the proffered record de novo, it held that the State proved by clear and convincing evidence that the proof was evident or presumption great that Warner committed a detainable offense, that he posed a real and present safety threat, and that no release conditions could mitigate that threat.
The court relied on the alleged strangulation of the same victim while Warner was already on pretrial release for an earlier alleged battery, his prior no-contact condition, his failure to appear, his risk-assessment scores, and his criminal history, including home invasion and unlawful possession of a weapon by a felon. Warner waived a hearing on the State’s revocation petition in the earlier case and did not challenge the revocation on appeal, so the court did not separately address it.
Key Takeaways
- A dangerousness finding alone does not justify detention; the State must also prove that no combination of conditions can mitigate the threat.
- Alleged violence against the same protected victim while on release can support a finding that a prior no-contact condition was insufficient.
- In a proffer-only detention proceeding, the appellate court independently reviews the documentary and proffered evidence.
Why It Matters
The decision illustrates how Illinois courts apply the Pretrial Fairness Act’s least-restrictive-conditions requirement in domestic-violence cases. A defendant’s alleged conduct while on release, prior nonappearance, risk assessments, and criminal history may collectively establish that supervision or additional conditions cannot adequately protect the victim or community.