Appealed from the District of Columbia Court of Appeals (Jan. 24, 2008)
Oral argument: March 31, 2010
CRIMINAL CONTEMPT, CIVIL PROTECTION ORDERS, SEPARATION OF POWERS
In March of 1999, Respondent Wykenna Watson obtained a civil protection order (“CPO”) against Petitioner John Robertson, alleging Robertson attacked her in March 1999. In June of 1999, Robertson violated his CPO when he attacked Watson again. In a plea bargain with the United States Attorney’s Office, Robertson agreed to plead guilty to attempted aggravated assault for the March incident in return for the United States’ agreement not to pursue two other charges arising from the June incident. Afterwards, Watson brought a criminal contempt action against Robertson, alleging that the June incident violated the CPO. The trial court convicted Robertson of three violations of his CPO, and Robertson subsequently petitioned to have his convictions vacated. Robertson argued that Watson’s criminal contempt action violated his plea bargain with the United States because criminal contempt proceedings are necessarily brought on behalf of the United States. In this case, the Supreme Court’s decision may alter criminal contempt proceedings in the face of plea bargains and affect the balance of power between the branches of government.