Legal Opinion

Benoit O. Brookens, II v. United States

District of Columbia Court of Appeals

Decided April 5, 2018No. 12-CM-1807 & 13-CO-937PublishedCited by 7 opinions

1Opinion of the Court

Easterly, Associate Judge:

Over thirty years ago, in 1986, appellant Benoit Brookens was found guilty of criminal contempt based on his unauthorized practice of law and was permanently enjoined from engaging in specified activities. In 2011, he was charged with nineteen counts of criminal contempt for violating the 1986 injunction and was ultimately convicted on four counts. We now reverse. Two of the four contempt counts are barred by the three-year catchall statute of limitations set forth in D.C. Code § 23-113 (a)(5), which we now hold applies to criminal contempt charges brought under D.C.…

2Cases cited45 opinions

  1. Board of Regents of Univ. of State of NY v. TomanioSupreme Court of the United States · 1980
  2. Bloom v. IllinoisSupreme Court of the United States · 1968
  3. Order of Railroad Telegraphers v. Railway Express Agency, Inc.Supreme Court of the United States · 1944
  4. Toussie v. United StatesSupreme Court of the United States · 1970
  5. Taylor v. HayesSupreme Court of the United States · 1974

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3Cited by7 opinions

  1. In re Wayne R. RohdeDistrict of Columbia Court of Appeals · 2018
  2. Argus Energy, LLC v. Clifford MarenkoWest Virginia Supreme Court · 2023
  3. C.C. v. G.D.District of Columbia Court of Appeals · 2024
  4. Fort Myer Constr. Co. v. BriscoeDistrict of Columbia Court of Appeals · 2023
  5. In re BlackwellDistrict of Columbia Court of Appeals · 2023

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