People v. Johnson

2026 IL App (1st) 260116

                                                                                 FIFTH DIVISION
                                                                                    April 20, 2026

                                         IN THE
                              APPELLATE COURT OF ILLINOIS
                                FIRST JUDICIAL DISTRICT

No. 1-26-0116B

 THE PEOPLE OF THE STATE OF ILLINOIS,                          )      Appeal from the
                                                               )      Circuit Court of
        Plaintiff-Appellee,                                    )      Cook County.
                                                               )
 v.                                                            )      No. 26 CR 19501
                                                               )
 QUADAJAH JOHNSON,                                             )      Honorable
                                                               )      Michael R. Clancy,
        Defendant-Appellant.                                   )      Judge Presiding.


       JUSTICE MIKVA delivered the judgment of the court, with opinion.
       Justice Oden Johnson* concurred in the judgment and opinion.
       Presiding Justice Mitchell dissented, with opinion.

                                            OPINION

¶1     Defendant Quadajah Johnson appeals from the circuit court’s order granting the State’s

petition to detain her before trial pursuant to section 110-6.1 of the Code of Criminal Procedure of

1963 (Code) (Pub. Act 104-417, § 1075 (eff. Aug. 15, 2025) (amending 725 ILCS 5/110-6.1)),

commonly known as the Pretrial Fairness Act. We reverse the circuit court’s detention order and

remand to that court to consider the conditions for Ms. Johnson’s pretrial relief.

¶2     In the petition for relief she filed in the circuit court, Ms. Johnson argued that the State

failed to establish by clear and convincing evidence that the proof was evident or the presumption

great that she committed first degree murder, which is the detainable offense she was charged with

(see id. (amending 725 ILCS 5/110-6.1(a)(1.5)), that she posed a real and present threat to

individuals or the community, and that no conditions could mitigate that threat. We agree with Ms.


*Justice Oden Johhnson is not related to defendant Quadajah Johnson
No. 1-26-0116B


Johnson that the State failed to carry its burden of showing that her release poses such a significant

threat that she cannot be released pending trial, with conditions.

¶3                                      I. BACKGROUND

¶4     On December 3, 2025, Ms. Johnson was arrested and charged with six counts of first degree

murder (720 ILCS 5/9-1(a)(1), (2) (West 2024)) for shooting and killing Romeca Blackmon,

several months earlier. The day after she was arrested, the State filed a petition seeking Ms.

Johnson’s pretrial detention.

¶5     The evidence that the State proffered at the hearing was that, on September 8, 2025, Ms.

Johnson was in a relationship with Carlos Smith, the father of her six-month-old child and the

child she was pregnant with. Mr. Smith was also the father of Ms. Blackmon’s six-year-old son.

¶6     Just before 8:30 a.m. on September 8, Mr. Smith drove Ms. Johnson and their baby from

his home to Ms. Johnson’s car, which was parked nearby. He double-parked his car and the two

of them moved their six-month-old from Mr. Smith’s car to a car seat in Ms. Johnson’s car. Ms.

Blackmon had just dropped her child off at a school across the street. Shortly after Ms. Johnson

secured her child in the backseat of her car, Ms. Blackmon drove past Ms. Johnson’s car, made an

immediate U-turn, and stopped with her car double-parked just behind Ms. Johnson’s car. This put

Ms. Johnson’s car between Ms. Blackmon’s and Mr. Smith’s.

¶7     Ms. Blackmon got out of her car and there were words exchanged between her and Ms.

Johnson. This confrontation was observed at various points by a number of witnesses, including

Mr. Smith.

¶8     According to the State, witnesses would describe how Mr. Smith stood between the women

and pushed Ms. Johnson away from Ms. Blackmon, who was standing in the open driver’s side

door of her vehicle. The State reported that evidence would show that one witness called 911 to



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No. 1-26-0116B


report a fight between two women and described observing Mr. Smith repeatedly pushing the door

of Ms. Blackmon’s car shut, hitting her with it. The witness testimony proferred by the State was

that Ms. Blackmon then got into her vehicle, and Ms. Johnson approached, threatening Ms.

Blackmon. Ms. Blackmon got back out of the car, and Mr. Smith placed her in a chokehold. Ms.

Blackmon tried to break free, with her hand in the air. Ms. Johnson threatened to shoot Ms.

Blackmon and retrieved a gun from her vehicle. Ms. Blackmon broke free from Mr. Smith and

stepped backwards. According to the State’s proffer, that was the point at which Ms. Johnson shot

Ms. Blackmon several times. According to the State, one witness reported that, after Ms. Johnson

shot Ms. Blackmon, Ms. Johnson and Mr. Smith celebrated with a fist bump.

¶9     Defense counsel argued that Ms. Blackmon was the aggressor and Ms. Johnson acted in

self-defense. Defense counsel advised the circuit court that Ms. Johnson had sought a stalking no-

contact order against Ms. Blackmon in December 2024, because Ms. Blackmon was repeatedly

calling and text messaging her and her family members and commenting on her social media in a

threatening manner. Defense counsel provided the State and the court with a transcript of the

hearing held regarding that no-contact order in June of 2025 and explained that Ms. Blackmon

threatened Ms. Johnson directly by text, until Ms. Johnson blocked her number and then Ms.

Blackmon sent threatening messages to others, including Ms. Johnson’s grandmother, in which

she said that she was going to kill Ms. Johnson. Ms. Blackmon was present at that June 2025

hearing on the no-contact order but did not make a subsequent appearance, and a default order of

protection was issued on July 14, 2025.

¶ 10   Counsel for Ms. Johnson argued that the witnesses at the scene told police that, after Ms.

Blackmon got out of the headlock, she rushed at Ms. Johnson’s car, with the six-month-old baby

inside, and that was when Ms. Johnson shot her. Defense counsel also argued that Ms. Blackmon



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No. 1-26-0116B


had boxed in Ms. Johnson’s car, by pulling up beside her, when Mr. Smith’s car was in front of

hers, preventing her from leaving.

¶ 11   On the issue of whether Ms. Johnson posed a threat to the community, defense counsel

emphasized that, except for a speeding ticket and a misdemeanor retail theft conviction, for which

she received supervision, Ms. Johnson had no criminal background. Ms. Johnson had a valid

Firearm Owners Identification (FOID) card and concealed carry license (CCL). She ran her own

eyelash business, volunteered in the community, and had just been accepted into a program to

become a dental assistant. Ms. Johnson was also the mother of a young baby and had just become

pregnant with a second child.

¶ 12   Counsel underscored that Ms. Johnson had sought and obtained a protective order against

Ms. Blackmon, that she stayed on the scene and waited for the police, that she cooperated with

them, and that the State waited almost three months, or until December 3, 2024, to arrest her.

¶ 13   The court granted the State’s petition for pretrial detention.

¶ 14   On December 22, 2025, Ms. Johnson filed a “Motion for Relief Pursuant to Illinois

Supreme Court Rule 604(h).” On January 7, 2026, Ms. Johnson filed an amended motion.

¶ 15   At the hearing on the motion, defense counsel provided the court with several exhibits,

which are also part of the record on appeal. Defense counsel argued that the video footage showed

that the State’s witnesses could not have seen or heard as much of the incident as they claimed and

that particularly witness three, who was the only witness to report the fist bump, was not in a

position to have seen Ms. Johnson after the shooting and did not report this alleged fist bump to

the police when she spoke to them initially.

¶ 16   Defense counsel also advised the court that Mr. Smith had reported to the police that Ms.

Blackmon approached Ms. Johnson, threatened her and then swung at her. He also reported that



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No. 1-26-0116B


Ms. Blackmon told Ms. Johnson, “I told you I was going to catch you,” and that Ms. Johnson told

Ms. Blackmon: “Leave me alone.” Defense counsel pointed to video evidence that showed Ms.

Johnson with her hair disheveled when police arrived on the scene, looking as if she had been

attacked.

¶ 17   At the hearing on her motion, defense counsel provided the court with the recording of a

911 call that was made regarding this confrontation, from an anonymous caller that reported that

the two women were fighting and that Ms. Blackmon was the aggressor.

¶ 18   The State argued that video footage from the officer’s body-worn camera after the shooting

showed that Ms. Johnson’s car had room to drive away. Defense counsel countered that her office

had been contacted by an additional witness who saw Mr. Smith start moving his car and that was

when Ms. Blackmon charged at and attacked Ms. Johnson and Ms. Johnson shot her. Counsel

argued that, based on that witness’s testimony, until Mr. Smith moved his car, Ms. Johnson could

not have driven away.

¶ 19   At the hearing on Ms. Johnson’s Motion for Relief, the State reiterated the proffer that it

had made at the initial detention hearing. The State also noted that the default order of protection

was never served on Ms. Blackmon so, while she knew Ms. Johnson was seeking an order of

protection, she may not have known one had been entered when she stopped her car and

approached Ms. Johnson, which would have violated that order. The State also noted that an

additional witness, not included in the previous proffer, would support the State’s characterization

that Ms. Johnson was the aggressor.

¶ 20   The court denied Ms. Johnson’s Motion for Relief. It noted that Ms. Johnson was alleged

to have shot Ms. Blackmon in broad daylight, near a school. The court emphasized that, except for

Mr. Smith, whom it did not believe was “an independent witness,” none of the other proffered



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No. 1-26-0116B


witnesses had reported seeing Ms. Blackmon ever striking Ms. Johnson, and they were all

consistent in saying that Ms. Blackmon appeared unarmed throughout the incident. The court

stated that it recognized Ms. Johnson “seems to have led a law-abiding life” but the facts of the

incident nevertheless indicated that she posed a real and present threat to the eyewitnesses and to

the community at large, which no conditions could mitigate.

¶ 21   Ms. Johnson filed a notice of appeal on January 8, 2026.

¶ 22                                   II. JURISDICTION

¶ 23   Ms. Johnson’s petition for relief was denied on January 8, 2026, and she timely filed a

notice of appeal that same day. We have jurisdiction over this appeal under section 110-6.1(j) of

the Code (Pub. Act 104-417, § 1075 (eff. Aug. 15, 2025) (amending 725 ILCS 5/110-6.1(j))) and

Illinois Supreme Court Rule 604(h) (eff. Apr. 15, 2024), which govern appeals from orders

denying the pretrial release of a criminal defendant.

¶ 24                                     III. ANALYSIS

¶ 25   Under the Pretrial Fairness Act: “All defendants shall be presumed eligible for pretrial

release.” Pub. Act 104-417, § 1075 (eff. Aug. 15, 2025) (amending 725 ILCS 5/110-6.1(e)). To

overcome this presumption, the State must seek pretrial detention by filing a timely, verified

petition. Id. (amending 725 ILCS 5/110-6.1(a), (c)).

¶ 26   Once the State has filed a petition, a defendant can be detained pending trial only where

the State shows by clear and convincing evidence that (1) “the proof is evident or the presumption

great” that the defendant committed a qualifying offense, (2) based on the facts of the case, the

defendant “poses a real and present threat to the safety of any person or persons or the community,”

and (3) “no condition or combination of conditions” provided in section 110-10(b) of the Code

can mitigate either that safety risk or “the defendant’s willful flight.” Id. (amending 725 ILCS



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No. 1-26-0116B


5/110-6.1(e)(1)-(3)).

¶ 27   Where, as in this case, the circuit court made its detention decision without hearing live

testimony, we are not bound by that court’s factual findings and should make our own de novo

determination of whether the State has met its burden on each of the statute’s three requirements.

People v. Morgan, 2025 IL 130626.

¶ 28   The Pretrial Fairness Act presumes that pretrial release is available for all charged crimes,

including murder. See, e.g., People v. Robinson, 2025 IL App (2d) 250123-U (reversing pretrial

detention and calling the suggestion that a murder defendant posed a threat to witnesses “pure

speculation” where there were no threats or contact of any kind between defendant and witnesses

during the 15-month period between the offense and arrest); People v. Thomas, 2025 IL App (4th)

251082-U (caretaker who knowingly administered a lethal dose of medication to a child to be

released because conditions could mitigate “the very specific nature” of the danger she posed);

People v. McCann, 2024 IL App (1st) 240892-U (defendant accused of shooting her former lover

at close range under disputed circumstances did not pose significant threat to anyone else); People

v.McDonald, 2024 IL App (1st) 232414 (defendant accused of shaking his baby to death entitled

to release where there were no other children he would be responsible for).

¶ 29   As these cases reflect, even in murder cases, a criminal defendant is to be released pending

trial unless the State has shown that the charged defendant “poses a real and present threat” to the

safety of any person or to the community, such that no condition could mitigate the safety risk.

Because we find that the State failed to carry its burden of making this showing as to Ms. Johnson,

we remand to the circuit court to consider the appropriate conditions for release.

¶ 30   The specific factors that courts are directed to consider in assessing whether a defendant

awaiting trial poses a threat are as follows:



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No. 1-26-0116B


      “(1)   The nature and circumstances of any offense charged, including whether the

      offense is a crime of violence, involving a weapon, or a sex offense.

      (2)    The history and characteristics of the defendant including:

             (A)     Any evidence of the defendant's prior criminal history indicative of violent,

             abusive, or assaultive behavior, or lack of such behavior. Such evidence may

             include testimony or documents received in juvenile proceedings, criminal, quasi-

             criminal, civil commitment, domestic relations, or other proceedings.

             (B)     Any evidence of the defendant's psychological, psychiatric or other similar

             social history which tends to indicate a violent, abusive, or assaultive nature, or lack

             of any such history.

      (3)    The identity of any person or persons to whose safety the defendant is believed to

      pose a threat, and the nature of the threat.

      (4)    Any statements made by, or attributed to the defendant, together with the

      circumstances surrounding them.

      (5)    The age and physical condition of the defendant.

      (6)    The age and physical condition of any victim or complaining witness.

      (7)    Whether the defendant is known to possess or have access to any weapon or

      weapons.

      (8)    Whether, at the time of the current offense or any other offense or arrest, the

      defendant was on probation, parole, aftercare release, mandatory supervised release, or

      other release from custody pending trial, sentencing, appeal, or completion of sentence for

      an offense under federal or State law.

      (9)    Any other factors, including those listed in Section 110-5” 725 ILCS 5/110-6.1(g)



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No. 1-26-0116B


       (West 2024).

¶ 31   We look first, under the statute, to the nature and circumstances of the crime. While Ms.

Johnson has been charged with an extremely serious and violent crime, this alleged crime was the

culmination of a very personal and specific controversy. There are undisputed facts about this

confrontation that undermine any claim that Ms. Johnson remains a danger to the community. It is

undisputed that Ms. Johnson did not seek out this confrontation. Rather, the victim confronted her.

It is also not disputed that, prior to this confrontation, Ms. Johnson sought and obtained a protective

order, a legal and appropriate path for avoiding any violent confrontation. It is undisputed that Ms.

Johnson remained at the scene and cooperated with the police, and it is undisputed that Ms.

Johnson had both a FOID card and a concealed carry license.

¶ 32   In many murder cases, the nature of the crime itself provides strong evidence that the

defendant presents a danger to the community or to other specific people. In a case involving a

murder incidental to a violent crime, gang activity, domestic violence, a mental health crisis, or a

random act, it is a relatively straightforward line from the State’s proffer of the expected trial

evidence to a showing that the defendant is a danger to the community. However, this case is

different because the alleged crime grows directly out of the relationship between these two

women. The fact that Ms. Johnson sought and received a no contact order against Ms. Blackmon

underscores the isolated nature of this conflict. Also, in this case the fact that this defendant had a

history of adhering to all legal requirements, and the fact that there is nothing in her background

to suggest any propensity for violent, abusive, or assaultive behavior, undermine any claim that

her release would pose a threat to others.

¶ 33   We look next to the history and characteristics of Ms. Johnson, herself. Her only criminal

history is for a nonviolent misdemeanor. The State presented no evidence to suggest that Ms.



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No. 1-26-0116B


Johnson has a mental health history or social history that reflects a danger to the community. Ms.

Johnson’s physical condition is that she is pregnant. While her pregnancy certainly does not

preclude violent actions on her part, its progression may well limit her ability to engage in them.

¶ 34   We also find it persuasive that Ms. Johnson remained at the scene until police arrived and

fully cooperated with them. In addition, although these events all occurred on September 8, 2025,

Ms. Johnson was not arrested until December 3, 2025. Thus, for almost three months she remained

out of custody but in touch with police as they continued to investigate this case. This fact also

demonstrates that she had not posed then, and likely will not pose if released, a threat to the other

witnesses involved in this case, as the circuit court suggested she might.

¶ 35   We also find this to be a case where conditions could be imposed that would mitigate

against any possible threat, and we remand to the circuit court for consideration of those

conditions. Very significant to us is the fact that Ms. Johnson had both a FOID card and a concealed

carry license for the gun that she used. This suggests that she would adhere to a court order banning

her possession or use of any firearms, which surely would be a condition of her release. For those

defendants who have been arrested and are awaiting trial for offenses involving illegal gun

possession, a ban on the possession of firearms is often viewed as an ineffectual condition of

release. However, for Ms. Johsnon, who it appears from the record has never owned a gun illegally,

this is a condition that could and should militate strongly against any threat.

¶ 36   Finally, we note that there is an additional consideration in this case, because, if the

detention order remains in place, Ms. Johnson could have to give birth while in jail. Before the

Pretrial Fairness Act was enacted, a separate 2019 provision in the bail statute required a hearing

before any pretrial defendant was required to give birth in custody. 725 ILCS 5/110-5.2 (West

2019). That provision, currently provides that “It is the policy of this State that a pre-trial detainee



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No. 1-26-0116B


shall not be required to deliver a child while in custody absent a finding by the court that continued

pre-trial custody is necessary to alleviate a real and present threat to the safety of any person or

persons or the community.” 725 ILCS 5/110-5.2 (West 2024).

¶ 37    The trial court, citing this section of the statute, suggested that Ms. Johnson’s pregnancy

would require renewed consideration of whether Ms. Johnson should remain in custody as her due

date approaches. However, for the reasons outlined above, we believe that Ms. Johnson should be

released sooner, rather than later, to prepare for and give birth to her baby, and to prepare with her

counsel for trial.

¶ 38    Our dissenting colleague suggests that we fail to appreciate the dangerous situation created

by Ms. Johnson’s firing shots on a public street with children around, when she shot Ms. Blackmon

on September 8 of last year. Of course we do and that may well be an appropriate consideration at

trial. But that is not the question now. Rather the question under the Pretrial Fairness Act is whether

Ms. Johnson would be such an ongoing threat to public safety that she must remain in custody

while she awaits that trial.

¶ 39    Trial will also be the right time to choose between the competing narratives of the

confrontation between Ms. Johnson and Ms. Blackmon. The dissent paints Ms. Johnson as the

clear aggressor, motivated by jealousy or anger at a romantic rival, rather than by fear for herself

and her six-month-old child. We have briefly laid out some of the contrary evidence in our

recitation of the facts and we recognize that it will be up to the trier of fact—not us—to decide if

this was murder or self-defense.

¶ 40    Finally, the dissent cites People v. Gage, 2026 IL App (1st) 252526-U and People v.

Martinez, 2025 IL App (1st) 250298-U, as support for its suggestion that this court is asking the

trial court to do the impossible in remanding to determine what conditions should be imposed on



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No. 1-26-0116B


Ms. Johnson’s release to protect the community. Those cases are, of course, totally different. Ms.

Gage was already on pretrial release in another case when she was arrested in the case cited.

Neither of these defendants waited for the police to arrive, cooperated fully with them and were

released for several months following the shooting. These very different facts in Ms. Johnson’s

case suggest that she will fully comply with whatever conditions of release are imposed including,

but not limited to, possessing no firearms, a condition that we direct the circuit court to include.

We trust that the trial court will be in the best position to decide which other conditions are

feasible, fair and protective.

¶ 41                                    VI. CONCLUSION

¶ 42    For the above reasons, we reverse the circuit court’s order granting the State’s petition for

pretrial detention and remand with directions to the circuit court to determine the conditions of

Ms. Johnson’s release.

¶ 43    Reversed and remanded.


¶ 44    PRESIDING JUSTICE MITCHELL, dissenting:

¶ 45    The suggestion that the murder of a romantic rival is “a very personal and specific

controversy” with no bearing on public safety is a dangerous fiction. It mistakes personal motive

for narrowness of risk: that defendant has already killed her victim does not support the conclusion

that she no longer presents “a real and present threat” to the community. Pub. Act 104-417, § 1075

(eff. Aug. 15, 2025) (amending 725 ILCS 5/110-6.1(e)(2)).

¶ 46    Our defendant gunned down her victim on a busy street in Chicago’s South Loop shortly

after 9:00 a.m. on a weekday morning. What began as a verbal altercation quickly escalated and

was witnessed by passersby. The incident took place in proximity to a school where the victim had

just dropped off her six-year-old child, a child fathered by Carlos Smith, who also fathered


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defendant’s six-month-old child (also on scene). According to a witness account, Smith struck the

victim with her own car door repeatedly and then had her in a chokehold while defendant went to

her car to retrieve her 9-millimeter handgun. The victim broke free from Smith and backed away.

Defendant then walked toward the victim, who was unarmed, fired a shot, paused, and then fired

two more shots. And with that, defendant and Smith fist-bumped.

¶ 47     What does this crime say about public safety? It says that when confronted with the

ordinary conflict inherent in human relations, defendant extinguished a life. And defendant did so

despite her firearm training and lawful licensing and despite her past willingness to abide by the

law. This killing was not merely intentional and avoidable violence, but it is violence unmoored

from proportion and restraint. Defendant chose to resolve her grievance not through withdrawal,

dialogue, or legal process, but through destruction of her rival. That choice is revealing. It

demonstrates a willingness to answer human conflict—common, recurring, and unavoidable—

with lethal force. Public acts of deadly violence demonstrate not just a willingness to kill, but a

willingness to do so without regard for surroundings, bystanders, or collateral consequences. A

defendant who has crossed that threshold once cannot be assumed to pose no danger of crossing it

again.

¶ 48     The condition prompting the shooting—an argument—can and will arise again. There is

no natural boundary confining that risk to a single victim. Further, in the pretrial period, an accused

undoubtedly faces enormous stress: the prospect of conviction and a lengthy criminal sentence,

the pressure of court proceedings, and concerns about witnesses and how they might testify. These

circumstances underscore that the risk posed by defendant is ongoing and not confined to a single,

now-deceased victim.




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No. 1-26-0116B


¶ 49    My esteemed colleagues in the majority elevate defendant’s lack of prior violent history to

near-controlling status. That is legal error. The statute lists criminal history as one factor among

many. See id. (amending 725 ILCS 5/110-6.1(g)(1)-(9)). The statute certainly does not confer a

get-out-of-jail-free card on first-time offenders accused of serious violent crimes. Indeed, the

absence of a prior violent criminal history in this case does not negate the significance of the crime

charged, but rather magnifies it by making the crime more inexplicable and defendant’s conduct

seemingly more unpredictable.

¶ 50    The majority disregards facts that firmly establish defendant’s dangerousness. Defendant

brought a gun to an argument with an unarmed victim, and the confrontation ended with defendant

unharmed and her victim dead with gunshots to her face and leg. And all this happened on a busy

city street in proximity to a school—a fact that is not in dispute. Astonishingly, the majority

declares “that may well be an appropriate consideration at trial,” but not when evaluating the risk

posed to the community in a pretrial detention hearing. That conclusion constitutes unmistakable

legal error.

¶ 51    Further, the majority’s confidence in largely unspecified conditions for release is

misplaced. Electronic monitoring cannot prevent murder. See, e.g., People v. Simpson, 2024 IL

App (4th) 240607-U, ¶ 40 (explaining that “[e]lectronic monitoring, regardless of the speed at

which law enforcement can be notified of a violation,” does not “provide much in the way

of prevention” (emphasis in original)); see also People v. Weyrick, 2022 IL App (3d) 200098-U,

¶¶ 4, 16, 19, 40 (recounting that the defendant committed first degree murder while wearing a GPS

ankle monitor). Firearm prohibitions can scarcely restrain an individual who, according to the

State’s proffer, resorted to lethal force in a matter of moments. See, e.g., People v. Gage, 2026 IL

App (1st) 252526-U, ¶¶ 28-29 (determining that no conditions would mitigate the threat the



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No. 1-26-0116B


defendant posed to anyone who triggered defendant’s temper where “defendant shot her friend

after a dispute about doing the dishes”). Geographic restrictions cannot anticipate confrontations

that might arise. See, e.g., People v. Martinez, 2025 IL App (1st) 250298-U, ¶ 38 (rejecting GPS

monitoring and agreeing with the State that “no condition short of detention would prevent [the

defendant] from having the ‘ability and opportunity to act on an impulse to engage in violent

behavior toward a member of the community and retaliate with deadly force after the individual

retreats’ ”). In granting the State’s petition to detain, the circuit court recognized the hard truth:

some risks are not meaningfully reduced through conditions.

¶ 52   If these facts—multiple gun shots on a busy street, an unarmed victim left dead, and a

celebratory fist bump—do not constitute clear and convincing evidence of a real and present threat,

then the statutory standard has been rendered meaningless. The Pretrial Fairness Act does not

require courts to wait for a second dead body before recognizing that a defendant “poses a real and

present threat” to the community.

¶ 53   For these reasons, I would affirm the order of detention. Accordingly, I respectfully dissent.




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No. 1-26-0116B




                 People v. Quadajah Johnson, 2026 IL App (1st) 260116B


Decision Under Review:       Appeal from the Circuit Court of Cook County, No. 26-CR-
                             19501; the Hon. Michael R. Clancy, Judge presiding.


Attorneys                    Ari Williams of Ari Williams Law, LLC, for appellant.
for
Appellant:


Attorneys                    Eileen O’Neill Burke, State’s Attorney, of Chicago (Joan F.
for                          Frazier, Special Assistant State’s Attorney, of counsel), for the
Appellee:                    People.




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