In re Jones, 51 A.3d 1290

Jones challenged a criminal contempt conviction for violating a Civil Protection Order (CPO).
The CPO prohibited conduct around the child and allowed unsupervised visitation only if Jones abstained from illegal drugs.
CSOSA administered periodic drug tests and prepared an Alleged Violations Report alleging multiple violations.
The violations included failure to abstain from substance abuse and failure to report for drug testing.
Judge Holeman found Jones guilty of two counts of criminal contempt and sentenced him to sixty days per count plus a fine.
On appeal, Jones contends the CPO did not make drug use a basis for contempt and that he lacked proper notice of such conduct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether drug use around the child supports contempt given CPO wording	Jones: CPO only ties abstinence to unsupervised visitation; no contempt for drug use	Akinola/State: drug use violated the CPO as a condition for visitation	Conviction reversed; no clear contempt basis for drug use
Whether the government proved willful disobedience beyond reasonable doubt	Jones contends there was no willful disobedience of a clear order	State argues evidence shows prohibition indirectly supported by CPO terms	Not satisfied; government failed to show willful disobedience under the CPO's terms
Whether due process required notice of the exact conduct that constitutes contempt	Jones argues he lacked notice that drug use could yield contempt	State argues CPO implied restriction on drug use around child	No clear notice of a contempt sanction for drug use; reversal warranted

In re Sobin, 934 A.2d 372 (D.C.2007) (elements of criminal contempt require willful disobedience of a protective order)
Ba v. United States, 809 A.2d 1178 (D.C.2002) (review of contempt judgments requires evidentiary support)
Resper v. United States, 527 A.2d 1257 (D.C.1987) (probation may not be revoked without breach of express conditions)
In re Robertson, 940 A.2d 1050 (D.C.2008) (contempt is to punish disobedience of a court order; due process requires notice)