Illinois Appellate Court
Criminal Court
Contempt
(Court opinion corrected 11/28/11.) Nightclub and owners were found in indirect criminal contempt for failure to comply with 2002 "mandatory order" in underlying suit alleging building code violations, alleging that nightclub and VIP rooms, located on second floor and mezzanine of building, were dangerous. In 2003, fight erupted at nightclub, and 21 people were killed and 50 injured in exit stampede after security guards used pepper spray to control crowd. Parties and court were under different understanding of order stating "Mandatory order not to occupy 2d floor", as order did not state whether it applied to building or nightclub. Order was not sufficiently specific for adjudication of contempt, which requires willful violation of specific order. (STEELE and QUINN, concurring.)