Illinois Supreme Court PLAs
Criminal Court
Contempt
This case presents question as to whether record adequately supported guilty verdict on charge of indirect criminal contempt relating to respondents' failure to comply with prior trial court order in building code violation proceeding that directed respondents not to occupy second floor of respondent's nightclub, which City claimed resulted in 21 dead and 51 injured patrons of respondent's nightclub after massive fight had broken out in said nightclub. Appellate Court, in rejecting City's proposed standard of review that would allow reversal only if evidence was against manifest weight of evidence, found that reversal of respondents' convictions was required where prior trial court order concerning occupancy of nightclub was ambiguous and did not provide respondents with reasonable details as to what actions were enjoined with respect to occupancy of said nightclub. Appellate Court also noted that respondents' alleged violation of trial court order had no causal relationship to injuries/deaths of respondents' patrons.