The Court of Appeals in an opinion issued in FREY v. U.S., compared and analyzed the legal difference between unlawful entry upon a “private” property versus a “public” property. In reversing the defendant’s conviction for unlawful entry on May 5, 2016 – the Court held that she had entered a public section of the Library of Congress and thus was entitled to a jury trial warranting reversal. The District of Columbia unlawful entry statute makes a legal distinction between entry upon a private v. public property. Specifically, subsection (a) of the code prohibits unlawful entry into “any private dwelling, building, or
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