People v. Morgan

Summary

The court held that the public-interest exception permits review of the otherwise moot appeal because the appropriate standard for reviewing pretrial detention decisions is a recurring issue of public importance. It held that a detention decision is reviewed under the manifest-weight standard when live testimony is presented, but that a reviewing court may independently review the evidence de novo when the hearing proceeds solely by proffer or other documentary evidence. Applying de novo review to Morgan’s proffer-based hearing, the court affirmed the order denying pretrial release.