In Re Commitment of Simons

Following a bench trial in the circuit court of Madison County, respondent, Stephen Simons, was found to be a sexually violent person under the Sexually Violent Persons Commitment Act (the Act) (725 ILCS 207/1 et seq. (West 2002)) and committed to the custody of the Department of Health and Human Services for control, custody, and treatment. Respondent appealed, arguing that the trial court erred in admitting certain expert testimony without first conducting a Frye hearing. See Frye v. United States, 293 F. 1013 (D.C. Cir. 1923). The appellate court agreed, reversed the trial court’s…