ANTOINETTE BOLZ v. DISTRICT OF COLUMBIA

149 A.3d 1130, 2016 D.C. App. LEXIS 427
CourtDistrict of Columbia Court of Appeals
DecidedDecember 8, 2016
Docket14-CF-956 to 14-CT-967
StatusPublished
Cited by7 cases

This text of 149 A.3d 1130 (ANTOINETTE BOLZ v. DISTRICT OF COLUMBIA) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ANTOINETTE BOLZ v. DISTRICT OF COLUMBIA, 149 A.3d 1130, 2016 D.C. App. LEXIS 427 (D.C. 2016).

Opinion

Easterly, Associate Judge:

In the fall of 2011, Occupy D.C. protesters began demonstrating in McPherson Square, a federal park. For weeks, they remained there with the tacit, if not express, permission of the federal authorities. Then, one morning in early December, they assembled a wooden structure in the park, the “Occubarn.” The United States Park Police told the protesters to take it down. The protesters did not. After an all-day standoff, the police cleared the area of the Occubarn and tore it down. In the course of these events, the police arrested a number of protesters for failing to obey an order to vacate a structure presumptively deemed unsafe under the Districts building regulations. These regulations do not apply to federal land, however, and the District of Columbia prosecuted these protesters under a different regulation—the Crowd and Traffic Control regulation—which makes it a crime to fail to obey a crowd and traffic clearing order. The District also prosecuted one protester, David Givens, for indecent exposure and disorderly conduct.

As a group, the protesters challenge their Crowd and Traffic Control convictions on grounds that the evidence was legally insufficient to establish that that they disobeyed a legitimate crowd and traffic clearing order. We agree. .The Crowd and.Traffic Control regulation does not authorize or require compliance with police orders to clear people from any public space at any time. Rather, the regulation only applies “[w]hen fires, accidents, wrecks, explosions, parades, or other occasions cause or may cause persons to collect” in the District’s public thoroughfares; and these “emergency occasion[s]” only empower police to issue, and demand compliance with, orders “necessary for the purpose of affording a clearing” of those thoroughfares to advance one of the listed objectives of the regulation. 24 DCMR §§ 2100.1-.2 (1983). Although these objectives broadly include the “protection of persons and property,” § 2100.1 (e), the purpose asserted by the District for the clearing order in this case, there must be a nexus between this objective and clearing crowds on the District’s public thoroughfares. Moreover, the safety concerns at issue must be substantiated.

We conclude that, although the .construction of the Occubarn constituted an “emergency occasion,” the protesters did not fail to comply with a “necessary ■ order.” The order was not “necessary for the purpose of affording a clearing” of a public thoroughfare because it cleared people from a public park. And, it was not “necessary ... for the protection of persons and property,” in the absence of evidence that the police had reason to believe the Occubarn posed a danger to anyone, in particular vis-a-vis crowds on public thoroughfares. As no reasonable factfinder could conclude that the protesters had an obligation to obey the order issued under the Crowd and Traffic Control regulation, we reverse *1134 their convictions thereunder. 1

Mr.' Givens separately challenges his conviction for indecent exposure, arguing that D.C. Code § 22-1312 (2016 Supp.) is unconstitutionally overbroad. Concluding that the statute is not substantially over-broad in relation to its plainly legitimate sweep, we affirm his conviction.

I. Facts and Procedural History

In the fall of 2011, protesters across the country “occupied” public spaces “to bring awareness to the[ir] concerns about United States economic policy, wealth disparity and the political process.” 2 At the beginning of October, the Occupy D.C. movement, established its base of operations in McPherson Square, a federal park close to the District’s corporate lobbying corridor on K Street NW. 3 The record does not establish whether the protesters had a permit to occupy the park, 4 but it appears that federal authorities did not challenge their presence in the park until December 4, 2011, when the events leading to the convictions now on appeal took place. 5

Before sunrise that morning, Occupy protesters began to assemble a wooden structure in the park, Resembling a barn, and thus earning the moniker “the Occu-barn,” the approximately 16 by 24 by 30 foot structure consisted of four modular framing pieces. The Occubarn was meant to be both functional, to protect the protesters from winter weather, and symbolic, to represent the foreclosure crisis, a central concern of their movement. Although the protesters planned to add walls and a roof, the framed space was largely open.

Later that morning, the U.S. Park Police arrived in McPherson Square and informed the protesters that the Occubarn had to be taken down. Apparently aware that federal regulations allow the use of temporary structures during demonstrations, 6 the protesters offered to show the police that the Occubarn was not permanent and could be taken apart; but according to one protester, the police “didn’t seem interested in that at all.” The police gave the protesters one hour to discuss the removal of the structure. The protesters held a meeting within the Occubarn but could not reach a consensus about how to proceed. About midday, ten to fifteen U.S. Park Police officers, some on horses, partially surrounded the structure. The mounted officers then rode into it, causing some protesters to climb into the rafters to get out of them way. Other protesters left the area of the Occubarn.

In the meantime, an inspector from the District’s Department of Consumer and Regulatory Affairs (DORA), received a request for assistance at McPherson Square. Arriving around 12:30 p.m., the inspector examined the Occubarn and saw no signs *1135 of imminent danger; instead he noted that “the building appeared pretty solid.” Nevertheless, because it seemed to have been erected without a building permit, he determined, pursuant to the District’s building regulations, that it “should not be occupied.” He came to this conclusion even though (as he later acknowledged at trial) the District’s building regulations do not apply to federal property. See 12A DCMR § 101.5 (2008) (exempting federal property from the District’s building regulations). He informed the on-site U.S; Park Police commander that the Occubarn should be “posted,” i.e., a “standard danger placard” should be affixed to the structure “indicating that it’s not safe.” 7 But the commander asked him to wait until the police had “done some more crowd control activities.”

Lieutenant Robert Lachance of the U.S. Park Police arrived at McPherson Square and assumed command of the scene late that afternoon. At that point, there were still about two dozen people inside the Occubarn. The lieutenant told them that “an inspector was going to come and look at the structure to see if it was safe.” -He also told them that if the remaining protesters were required to leave the Occu-barn, he would give them multiple warnings and anyone who left before he gave the final warning would not be arrested.

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Bluebook (online)
149 A.3d 1130, 2016 D.C. App. LEXIS 427, Counsel Stack Legal Research, https://law.counselstack.com/opinion/antoinette-bolz-v-district-of-columbia-dc-2016.