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IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA, )

)

Plaintiff, )

v. ) 

) No. 20 CR 447

KOSHUAN HUGHES, ) Judge Robert W. Gettleman

)

)

Defendant. )

KOSHAUN HUGHES’ MOTION FOR RELEASE FROM CUSTODY 

 

NOW COMES Defendant, KOSHUAN HUGHES, through his counsel, 

QUINN A. MICHAELIS, and respectfully requests that this honorable court set 

a bond in this matter and release Mr. Hughes from custody. In support of his 

motion, Mr. Hughes states the following.

BACKGROUND FACTS 

On August 6, 2020, Mr. Hughes appeared before the court for a detention 

hearing, at which point he waived his right to a detention hearing without 

prejudice. On August 27, 2020, Mr. Hughes was charged with one count of being 

a felon in possession of a firearm, pursuant to 18 U.S.C. §922(g).

DANGER TO THE COMMUNITY 

Mr. Hughes is not a danger to the community. Even taking the 

govenrment’s statement of the events leading up to Mr. Hughes’ arrest as true, 

Mr. Hughes complied with the orders of the police when they pulled him over on 

the date of his arrest. He did not attempt to flee and was cooperative with the 
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officers. The government cannot present any evidence that would indicate that 

Mr. Hughes was acting violently of that he intended to perpetrate some sort of 

violent crime. 

Further, Mr. Hughes’ criminal history illustrates that he is not a violent 

person. He has no previous convictions for gun possessions. The majority of Mr. 

Hughes’ arrests are cannabis cases, most of which are expungeable under 20 ILCS 

2630/5.2(a)(1)(G-5)). 

REBUTTABLE PRESUMPTION 

Because the maximum term of imprisonment for the charged offense is 10 

years, there is a rebuttable presumption of detention. 18 U.S.C. §3142(e). Mr. 

Hughes’ previous convictions for non-violent drug offenses should rebut any 

claim that he should be detained as a danger to the community. 

Additionally, Mr. Hughes’ connections to the Northern District of Illinois 

are substantial. Mr. Hughes’ girlfriend and their 2 year old daughter live in 

Rockford, Illinois. Prior to Mr. Hughes’ arrest, he had been unemployed due to 

the global health crisis and took care of his young daughter during the day. Mr. 

Hughes’ mother and siblings all live in Chicago, including his cousins, who are 

proposed third party custodians Mr. Hughes’ ties to the area are so strong that 

they rebut the presumption that he would flee and thereby disconnect himself 

from the only support network he has. He has lived in the Northern District of 

Illinois his entire life. Mr. Hughes’ personal history and connections to the area 

rebut the presumption that he poses a flight risk. 
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The presumption of detention is further rebutted by the fact that both of 

his cousins in Chicago have offered to act as third-party custodians, and allow 

him to live at their homes if the court does not allow him to return to his own 

home with his girlfriend and daughter. Furthermore, his cousin, Latoya Jones, 

has offered to help Mr. Hughes look for employment if he is released, as her 

residence is down the street from a temporary staffing agency. Ms. Jones’ has 

three children who are all attending school virtually currently and Mr. Hughes 

can assist them with their schoolwork during the day as well. 

Nature Of The Offense 

As noted above, the nature of the offense creates a rebuttable presumption 

of detention. However, Mr. Hughes’ family’s faith in him, his lack of violent 

criminal history, the nature of his alleged involvement in the possession of the 

firearms all militate against his detention. There is no evidence that Mr. 

Hughes ever used or threatened to use the firearms connected with the charged 

offense. The government’s complaint fails to establish that Mr. Hughes actively 

participated in any violent activity whatsoever. Hence, Mr. Hughes’ alleged 

conduct in the instant offense does not indicate that he poses a danger to the 

community or that he poses a risk of flight. 
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WHEREFORE, Mr. Hughes asks the Court to release him to the custody 

of his cousin, Latoya Jones, on whatever conditions the court deems appropriate, 

pending resolution of this case. 

Respectfully Submitted,

s/ Quinn A. Michaelis

Quinn A. Michaelis

Attorney for Koshaun Hughes

73 W. Monroe, Suite 106

Chicago, IL 60603

312-714-6920

CERTIFICATE OF SERVICE

I, Quinn A. Michaelis, an attorney, certify that in accordance with Fed. R. 

Crim. P. 49, Fed R. Civ. P. 5, LR5.5, and the General Order on Electronic Case 

Filings (ECF), the following document: 

KOSHAUN HUGHES’ MOTION FOR RELEASE FROM CUSTODY 

 

was served on January 19 2021, to all parties of record via the CM/ECF system.

s/ Quinn A. Michaelis

Quinn A. Michaelis 

Attorney for Koshaun Hughes

73 W. Monroe, Suite 106

Chicago, IL 60603

312-714-6920