Public-domain · open source
OpenJurist

2025 IL 131279

People v. Grayson

Illinois Supreme Court

Decided November 20, 2025

Illinois Supreme Court · decided 2025-11-20

Relies on 96 Ill. 2d 273 - People Ex Rel. Black v. Dukes · 216 Ill. 2d 287 - In Re Marriage of Peters-Farrell

Decided 2025-11-20

2025 IL 131279



                                            IN THE
                                   SUPREME COURT
                                                OF
                             THE STATE OF ILLINOIS




                                       (Docket No. 131279)

     THE PEOPLE OF THE STATE OF ILLINOIS, Appellant, v. SEAN GRAYSON, Appellee.


                                 Opinion filed November 20, 2025.



           PER CURIAM



                                             OPINION

¶1          The cause coming to be heard on appeal from the appellate court, this court
        finds and orders as follows. On July 18, 2024, Sean Grayson, a Sangamon County
        sheriff’s deputy, was indicted by a grand jury on three counts of first degree murder,
        on one count of aggravated battery with a firearm, and on one count of official
        misconduct for causing the death of Sonya Massey. The State filed a petition to
        deny Grayson pretrial release on the grounds of dangerousness.

¶2          On July 18, 2024, after a hearing, the circuit court of Sangamon County granted
        the State’s petition and detained Grayson, finding that the State presented clear and
     convincing evidence that Grayson should be detained. On appeal, the appellate
     court disagreed and reversed the circuit court’s judgment. 
2024 IL App (4th) 241100-U
. The State appealed to this court, arguing that its proffer constituted clear
     and convincing evidence that Grayson was ineligible for pretrial release.

¶3       During the pendency of this appeal, Grayson’s case went to trial, and he was
     found guilty of second degree murder. Because Grayson’s case went to trial and a
     jury found him guilty of second degree murder, we find that the detention question
     presented in this appeal has become moot. “An appeal is moot if ‘no actual
     controversy exists or if events have occurred that make it impossible for the
     reviewing court to grant the complaining party effectual relief.’ ” In re Marriage of
     Eckersall, 
2015 IL 117922
, ¶ 9 (quoting In re Marriage of Peters-Farrell, 
216 Ill. 2d 287, 291
 (2005)).

¶4       As this court has explained, “when an appeal is rendered moot and we do not
     reach the merits of the appeal, we cannot speak to the correctness of the judgments
     rendered by the circuit and appellate courts.” Id. ¶ 20. “Thus, to preclude the lower
     courts’ resolution of the issues from standing as precedent for future cases, the
     lower courts’ judgments should be vacated.” Id.; see People ex rel. Black v. Dukes,
     
96 Ill. 2d 273, 278
 (1983). Therefore, we dismiss the cause as moot. To prevent the
     lower courts’ resolution of the issues presented to it from standing as precedent for
     future cases, we vacate the judgment of the appellate court and the judgment of the
     circuit court.


¶5      Judgments vacated.

¶6      Appeal dismissed.




                                             -2-

/2025/il/131279 · .json · Public domain