Gilberto Lopez-Ramirez v. United States, 171 A.3d 169

Gilberto Lopez‑Ramirez was tried in a bench trial, convicted of attempted misdemeanor sexual abuse and acquitted of three contempt counts; he asked for a jury trial before trial.
D.C. law (D.C. Code § 4‑516) requires mandatory WCCA assessments on convictions: $50–$250 for misdemeanors and $100–$5,000 for felonies, collected "as fines."
D.C. Code § 16‑705(b)(1)(B) lets a defendant demand a jury when charged with 2+ offenses punishable by a cumulative fine/penalty > $4,000 (or imprisonment > 2 years).
Lopez‑Ramirez argued WCCA assessments should count toward the § 16‑705 monetary threshold, which would have made his multi‑count exposure exceed $4,000.
The trial court denied the jury demand, concluding WCCA assessments are not "fines" for § 16‑705; the D.C. Court of Appeals affirmed but remanded to correct the sentence (attempted misdemeanor carries a lower max than completed offense).

Issue	Lopez‑Ramirez's Argument	Government/Respondent's Argument	Held
Whether WCCA assessments count as a "fine or penalty" under D.C. Code § 16‑705 for jury‑demand threshold purposes	WCCA assessments are punitive monetary burdens imposed after conviction and thus should be aggregated into the § 16‑705 fine/penalty thresholds	WCCA assessments are statutory "assessments" imposed "in addition to and separate from punishment" and were not intended by the Council to be treated as fines for § 16‑705 purposes	Majority: WCCA assessments do not count as "fines or penalties" for § 16‑705 jury‑demand calculations; jury demand was properly denied

Gotay v. United States, 805 A.2d 944 (D.C. 2002) (characterizing WCCA payments as "assessments," not "fines")
Lewis v. United States, 518 U.S. 322 (1996) (no Sixth Amendment jury right for multiple petty offenses)
United States v. Nachtigal, 507 U.S. 1 (1993) (no constitutional jury right for petty offenses despite large statutory fines)
Grayson v. AT & T Corp., 15 A.3d 219 (D.C. 2011) (statutory words given natural meaning; legislative intent governs construction)
O’Rourke v. District of Columbia Police & Firefighters' Ret. & Relief Bd., 46 A.3d 378 (D.C. 2012) (statutes read in context of overall scheme)
Ferguson v. United States, 157 A.3d 1282 (D.C. 2017) (ambiguous penalty terms considered in statutory context)
District of Columbia Office of Tax & Revenue v. Sunbelt Beverage, LLC, 64 A.3d 138 (D.C. 2013) (literal meanings rejected when producing absurd results)
Peoples Drug Stores v. District of Columbia, 470 A.2d 751 (D.C. 1983) (courts may decline literal statutory reading to effectuate legislative purpose)
United States v. Mayberry, 774 F.2d 1018 (10th Cir. 1985) (factors indicating assessments function as punishment)
Colter v. United States, 37 A.3d 282 (D.C. 2012) (court regularly adds mandatory post‑conviction assessments to sentence)