In re Robertson

19 A.3d 751 (2011)

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In re Robertson

District of Columbia Court of Appeals
19 A.3d 751 (2011)

  • Written by Haley Gintis, JD

Facts

On March 27, 1999, John Robertson (defendant) violently attacked his girlfriend, Wykenna Watson (plaintiff). The superior court’s domestic-violence unit issued a civil protective order (CPO), which prohibited Robertson from assaulting, threatening, or contacting Watson. Additionally, the superior court’s criminal division charged Robertson with aggravated assault. On June 26, Robertson violently assaulted Watson again. In response, the United States Attorney’s Office (OAG) and Robertson entered into a plea agreement. Under the agreement, Robertson pleaded guilty to the March 27 incident and the OAG agreed not to pursue any criminal charges against Robertson for the June 26 incident. In January 2000, Watson filed a criminal-contempt action against Robertson for violating the CPO. Robertson was convicted and moved to vacate the conviction. The court denied the motion. Robertson appealed to the United States Supreme Court on the ground that a private person may not file a criminal-contempt action. The Court dismissed the case. Robertson then motioned for a rehearing. The District of Columbia Court of Appeals granted the rehearing to consider whether a private person may initiate a criminal-contempt action and, if so, whether the plea agreement barred Watson from filing the action.

Rule of Law

Issue

Holding and Reasoning (Reid, J.)

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