Horsman v. Headley

On November 6, 2025, the U.S. District Court for the Northern District of Illinois ruled in Horsman v. Headley. Sarah Horsman had obtained a domestic violence protective order against her ex-partner James Headley after a documented history of physical abuse. Despite the order, Headley repeatedly sent threatening electronic messages and appeared at her workplace and residence, violating the order on at least seven occasions over two months. Horsman filed a motion for civil contempt, but the court, given the willful and terrorizing nature of the violations, elected to treat the matter as criminal contempt. Evidence included GPS tracking data, text message logs, and sworn testimony from neighbors. The court found Headley guilty beyond a reasonable doubt, sentencing him to 12 months of imprisonment and a $5,000 fine. The ruling underscored that protective orders carry criminal enforcement mechanisms and survivors will receive robust judicial protection.

James Headley was convicted of criminal contempt, sentenced to 12 months in jail and ordered to pay a $5,000 fine. The court also extended the protective order for an additional five years with electronic monitoring conditions.

Whether the defendant's repeated and willful actions constituted criminal contempt rather than merely civil contempt, and whether the protective order was validly served and violated under the required criminal standard of proof.

The case drew national attention to the enforcement of protective orders and strengthened the precedent that repeated, willful violations can lead directly to criminal penalties. It prompted several states to review and tighten their own contempt statutes, and domestic violence advocacy groups cited the decision as a crucial step in holding abusers criminally accountable while empowering survivors to seek justice.