In re the Commitment of Wyatt

── In re the Commitment of Wyatt ── Court: Appellate Court of Illinois Date: June 05, 2026 Category: General NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). 2026 IL App (3d) 250332-U Order filed June 5, 2026 __________________________________________________________________________ IN THE APPELLATE COURT OF ILLINOIS THIRD DISTRICT 2026 In re the COMMITMENT OF ) Appeal from the Circuit Court WILLIE WYATT, JR. ) of the 21st Judicial Circuit, ) Kankakee County, Illinois, (The People of the State of Illinois, ) ) Petitioner-Appellee, ) Appeal No. 3-25-0332 ) Circuit No. 21-MR-16 v. ) ) Willie Wyatt, Jr., ) Honorable ) Kathy S. Bradshaw Elliot, Respondent-Appellant). ) Judge, Presiding. __________________________________________________________________________ JUSTICE BERTANI delivered the judgment of the court. Justices Brennan and Anderson concurred in the judgment. __________________________________________________________________________ ORDER ¶1 Held: The circuit court did not err in finding that the State met its burden of proving beyond a reasonable doubt that respondent was a sexually violent person even though two experts offered differing opinions; the court did not abuse its discretion when it detained respondent to a secure facility for further treatment. ¶2 Respondent, Willie Wyatt, Jr., appeals the Kankakee County circuit court’s decision finding him a sexually violent person (SVP). He contends that the experts’ differing opinions regarding whether he should be labeled as such constituted reasonable doubt. He also appeals the  court’s decision to detain him in a secure facility, arguing that he should have been placed on conditional release. For the reasons that follow, we affirm. ¶3 I. BACKGROUND ¶4 On January 13, 2021, the State filed a petition against Wyatt pursuant to the Sexually Violent Persons Commitment Act (Act) (725 ILCS 207/1 et seq. (West 2020)), seeking to have Wyatt adjudicated an SVP and committed to the care and custody of the Department of Human Services (DHS). The petition alleged that Wyatt had previously been convicted of aggravated criminal sexual assault, which is a sexually violent offense as defined by the Act. Id. § 5(e)(1). Wyatt had been evaluated by a clinical psychologist who had diagnosed him as suffering from a qualifying mental disorder. Finally, the petition alleged that Wyatt was dangerous to others because these mental disorders made it substantially probable that he would commit acts of sexual violence in the future. The circuit court found probable cause to believe Wyatt was an SVP and ordered him detained pending an evaluation by DHS and a trial regarding whether he should be found to be an SVP. ¶5 Wyatt waived a jury trial and proceeded to a bench trial on September 26, 2023. The State called Doctor Amy Louck Davis as its expert witness. She testified that she conducted an evaluation to determine whether Wyatt met the criteria to be found an SVP. In order to reac