People ex rel. City of Chicago v. Le Mirage, Inc, 2013 IL 113482

Two-story building at 2347 S. Michigan Ave; building court order barred occupancy of the second floor due to hazardous VIP rooms/mezzanine construction.
July 19, 2002 hearing led to an order that the second-floor VIP rooms not be occupied; court noted agreement not to occupy the second floor.
August 9, 2002 and October 25, 2002 orders reaffirmed not to occupy the second floor; all prior orders remained in effect.
Respondents continued operating E2 on the second floor; February 17, 2003 fight led to a deadly stampede and 21 deaths; City filed indirect criminal contempt petition.
Trial jury convicted Hollins and Kyles of indirect criminal contempt; appellate court reversed, finding the orders ambiguous and not proving guilt beyond a reasonable doubt.
We reverse the appellate court and remand for consideration of issues raised that the appellate court did not address.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are the building court orders clear enough to support contempt?	Hollins	Hollins	Orders were clear and unambiguous.
Was the half sheet/Prendergast letter admissible or necessary to interpret the orders?	City	Respondents	Not necessary to undermine clarity; does not render the orders unclear.
Was the evidence sufficient to prove willful violation beyond a reasonable doubt?	City	Respondents	Yes; rational jury could find willful violation.
Did the appellate court err in reversing on ambiguity grounds and voiding the convictions?	City	Respondents	Appellate court erred; convictions restored.

People v. Simac, 161 Ill. 2d 297 (1994) (contempt and its essential requirements)
Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency standard for criminal conviction review)
O’Leary v. Allphin, 64 Ill. 2d 500 (1976) (injunctions must be clear to support contempt)
International Longshoremen’s Ass’n, Local 1291 v. Philadelphia Marine Trade Ass’n, 389 U.S. 64 (1967) (fundamental postulates against penalties for incomprehensible commands)