Grayton v. United States, 50 A.3d 497

Appellant Mosiah Grayton was convicted of two counts of criminal contempt for alleged violations of a June 18, 2010 preliminary injunction stay-away order.
The injunction forbade Grayton from contacting Mary Jackson or coming within 100 feet of Jackson’s home for one year (June 18, 2010–June 18, 2011).
The government charged Grayton with violations on August 3, 2010, and January 14, 2011; the January 14 incident also involved an attempted threats count.
Evidence for the August 3, 2010 violation relied solely on testimony that Christopher, Jackson’s grandson, said a girl was outside near B Street, with no proof of Grayton’s proximity.
On January 14, 2011, Jackson received a threatening call from Grayton; testimony and officer-supervised interviews later included admissions and a third-party call, leading to contempt and attempted-threats findings.
The trial court denied suppression and acquittal motions, and Grayton was later sentenced on the contempt counts; the issue on appeal concerns sufficiency of the August 3, 2010 evidence and related procedural challenges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of August 3, 2010 evidence	Grayton argues insufficient evidence; hearsay from Christopher is unreliable for stay-away violation.	Grayton contends evidence could not establish proximity or violation beyond speculation.	Conviction reversed; August 3, 2010 violation not proven beyond a reasonable doubt.
Miranda applicability of statements on January 20, 2011	Grayton contends suppression due to Miranda violations for two statements.	Government contends no Miranda error; one statement not custodial interrogation, the other not coerced.	No Miranda error; suppression denial affirmed.
Judicial trial rights under charging statute	Grayton argues failure to prove pretrial release status made §23-1329 inapplicable; possible amendment to §11-944 violated jury-trial rights.	Record shows no prejudice; information was specific; no right to jury trial because sentences were suspended concurrent terms.	No reversible error; information sufficient; no jury-trial right applicable given sentencing.

Minnesota v. Murphy, 465 U.S. 420 (1984) (probing custodial interrogation; probation interview not custodial for Miranda)
Rhode Island v. Innis, 446 U.S. 291 (1980) (interrogation and elicitation for Miranda purposes)
Davis v. United States, 834 A.2d 861 (D.C. 2003) (standard for sufficiency of evidence; beyond reasonable doubt in contempt)
Nowlin v. United States, 782 A.2d 288 (D.C. 2001) (weight given to inferences and credibility at trial)
Boddie v. United States, 865 A.2d 544 (D.C. 2005) (contrast on distance-based inference for proximity to prohibited area)
Frank v. United States, 395 U.S. 147 (1969) (jury trial rights tied to offense seriousness and actual sentence)
Grant v. United States, 734 A.2d 174 (D.C. 1999) (pretrial contempt charging; factual sufficiency and notice)
Byrd v. United States, 579 A.2d 725 (D.C. 1990) (notice and specificity in charging; variance not fatal without prejudice)
Brookens v. Comm. on Unauthorized Practice of Law, 538 A.2d 1120 (D.C. 1988) (non-petty contempt threshold and sentencing considerations)