Williams v. United States, 51 A.3d 1273

Williams, the appellant, was charged with multiple offenses arising from domestic-violence incidents with Flood.
The incidents include December 3, 2005 knife threat, December 24–25, 2005 property destruction, and March 4, 2006 arrest/phone call editing.
A stay-away order issued October 25, 2005 prohibited him from the 3300 block of Blaine Street, but the order was not entered into evidence.
Jury convicted Williams of destruction of property, first-degree theft, contempt, and obstruction of justice; other charges were dismissed or acquitted.
The court sentenced Williams to seven months for contempt and concurrent terms for the other convictions; the appeal challenges the contempt, unanimity, and public-trial issues as well as voir-dire closure.
The court affirms all convictions, addressing sufficiency of the contempt evidence, the jury instructions, unanimity, and public-trial concerns.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Contempt sufficiency of evidence	Government argues there was sufficient evidence Williams violated the stay-away order.	Williams contends no proof the order was in effect during the charged period.	Evidence supports contempt; order was in effect at least partly during the charged period.
Contempt willfulness instruction	Government asserts instruction correctly defined willfulness.	Williams claims the instruction misled by suggesting lack of knowledge of the order.	No plain error; instruction reasonably conveyed willfulness given stipulation that Williams understood the order.
Unanimity instruction	Government maintains unanimity instruction was unnecessary for multiple incidents.	Williams asserts lack of instruction could allow non-unanimous basis for conviction.	Failure to give unanimity instruction not reversible; evidence supported unanimous verdict on key incidents.
Right to public trial (voir dire closure)	Government argues accommodation for disability warranted closure.	Williams argues closure violated public-trial right.	Partial voir-dire closure was plain error but not reversible; balancing public-access with accommodation required.

Davis v. United States, 834 A.2d 861 (D.C.2003) (contempt requires willful disobedience of a court order)
Payne v. United States, 932 A.2d 1095 (D.C.2007) (willful disobedience shown by intentional actions contradicting order)
Grant v. United States, 734 A.2d 174 (D.C.1999) (willful disobedience entails knowledge of proscribed conduct)
Barrows v. United States, 15 A.3d 673 (D.C.2011) (structural error in closure; public-trial considerations)
Presley v. Georgia, 130 S. Ct. 721 (U.S.2010) (public trial rights extend to voir dire)