In re Prosecution of Clinton Perrow

172 A.3d 894
CourtDistrict of Columbia Court of Appeals
DecidedNovember 9, 2017
Docket16-SP-1148
StatusPublished
Cited by4 cases

This text of 172 A.3d 894 (In re Prosecution of Clinton Perrow) 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
In re Prosecution of Clinton Perrow, 172 A.3d 894 (D.C. 2017).

Opinion

Blackburne-Rigsby, Chief Judge:

In 2006, the Council of the-District, of Columbia (“D.C. Council”) enacted the Omnibus -Public Safety Amendment Act of 2006, which expressly criminalized and defined the crime of “voyeurism” in the District of Columbia, codified as -D.C. Code § 22-3531 (2013 Supp.). 1 Section (g) of the statute designated, the “Attorney General for the District of Columbia” as the prosecuting authority for this offense. This matter has been certified to this court by a judge from the Superior'Court of the District of Columbia, pursuant to D.C. Code § 23-101 (f) (2012 Repl.), 2 for this court to consider whether the D.C. Council’s assignment of prosecutorial authority for this new offense to the Office of the Attorney General is valid.

The D.C. Council’s authority to designate the Office of the Attorney General as the prosecuting authority for new, criminal offenses is limited by the District of Columbia Court Reform and Criminal Procedure Act of 1970 (“Court Reform Act”) and the District of Columbia Home Rule Act (“Home Rule Act”). Together, these congressional acts clarify that the D.C. Council may only assign the Office of the Attorney General as the prosecutorial authority for certain, designated offenses, specifically: (1) “violations of all police or municipal ordinances or regulations,” (2) “violations of all penal statutes in the nature of police or municipal regulations, where the maximum punishment is a fine only, or imprisonment not exceeding one year,” and (3) prosecutions of “disorderly conduct” or “lewd, indecent, or obscene acts.” D.C. Code § 23-101 (a)-(b) (2012 Repl). The offense of “voyeurism” is a relatively new general offense with elements different from those of “disorderly conduct” or “lewd,- indecent, or obscene acts.”- It also cannot be categorized as either an offense violative of a police or municipal ordinance or regulation, or of a penal statute .in the nature of a regulation. Thus, we hold that section (g) of the District’s voyeurism statute infringes on “the duties or powers of the United States Attorney,” in violation of the Home Rule Act. D.C. Code § 1-206.02 (a)(8) (2012 Repl.). Pursuant to D.C. Code § 23-101 (c), prosecutorial authority for this new offense vests in the Office of the United States Attorney for the District of Columbia, as required by Congress.

I. Factual Background

The United States Attorney’s Office (“USAO”) charged Mr. Clinton Perrow by information with one count of misdemean- or voyeurism in violation of D.C. Code § 22-3531 (d). 3 The government alleged that Mr. Perrow used his cell phone to record a woman’s “private area” 4 underneath her dress without her knowledge or permission. Mr. Perrow, through counsel, filed a motion to dismiss the information on the ground that USAO was not the proper prosecuting authority because prosecution of the offense of voyeurism rests “exclusively” with the Office of the Attorney General (“OAG”), as stated in section (g) of the voyeurism statute.' See D.C. Code § 22-3531 (g). USAO opposed the motion, arguing that the D.C. Council may not designate OAG as the prosecuting authority for new offenses that fall outside those offenses specifically assigned by Congress for OAG to prosecute under D.C. Code § 23-101. The trial judge subsequently certified to this court the question of whether D.C. Code § 22-3531 (g) designating OAG as the proper prosecuting authority for voyeurism is valid.

II. Discussion

Prosecutions of criminal offenses in the District of Columbia ¿re “bifurcated” between the federal Office of the United States Attorney for the District of Columbia and the local Office of the Attorney General of the District of Columbia. United States v. Bailey, 495 A.2d 756, 760 n.10 (D.C. 1985). This bifurcation of prosecuting authoritywas delineated by Congress pursuant to its enactment of the District of Columbia’s Court Reform Act and codified under D.C. Code § 23-101. “Neither the Council nor the electors of the District of Columbia can overrule acts of Congress.” Hessey v. District of Columbia Bd. of Elections and Ethics, 601 A.2d 3, 16 (D.C. 1991).

Specifically, Congress designated OAG to prosecute violations of “police or municipal ordinances or regulations” in the District of Columbia. D.C. Code § 23-101 (a). 5 Consequently, the D.C. Council may designate OAG as the prosecuting authority for new or revised police or municipal ordinances or regulations “irrespective of the fact that violation of these provisions [may carry] a maximum penalty of both a fine and imprisonment.” In re Hall, 31 A.3d 453, 456 (D.C. 2011). Congress also designated OAG to prosecute “all penal statutes in the nature of police or municipal regulations, where the maximum punishment is a fine only or imprisonment not exceeding one year D.C. Code § 23-101 (a) (emphasis added). We have clarified that this limitation on punishment (fine only or imprisonment of not more than one year) pertains only to OAG’s authority to prosecute penal statutes in the nature of police or municipal regulations. District of Columbia v. Smith, 329 A.2d 128, 130 (D.C. 1974). OAG retains “prosecutorial jurisdiction over all police [or municipal] regulation violations, regardless of potential penalty ....” Id.

Additionally, Congress designated OAG as the prosecuting authority for violations of D.C. Code § 22-1321 (2012 Repl.), “relating to disorderly conduct,” and violations of D.C. Code § 22-1312

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Bluebook (online)
172 A.3d 894, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-prosecution-of-clinton-perrow-dc-2017.