Simon v. United States

Appellants challenge their convictions for unlawful entry, D.C.Code § 22-3102 (1989), *306based on their refusal to leave the Library of Congress at a new closing hour when an authorized person ordered them to do so. Only one issue merits discussion, and in all respects we affirm.1

Because of “First Amendment considerations,” we have interpreted § 22-3102 “to require some additional specific factor beyond the mere direction of an authorized person to leave the property in order to make a person’s presence on public property illegal.” Shiel v. United States, 515 A.2d 405, 408 (D.C.1986), cert.…