The Court of Appeals in Holmon v. D.C., decided on February 28, 2019, determined whether a Civil Protection Order violation resulting in conviction based on hearsay evidence at trial should be reversed. First to establish the elements of a CPO violation, the government must prove beyond a reasonable doubt that defendant had engaged in: (1) Willful disobedience (2) Of a protective court order. It is not a willful violation if: Petitioner approached the respondent without his encouragement or consent, The contact was necessitated by an emergency, or There also existed some other compelling reason. Even in the enumerated exceptions listed
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