The following excerpt is from Powell v. Ward, 643 F.2d 924 (2nd Cir. 1981):
12 Assuming that an appropriately clear order has obviously not been complied with, a defendant should not be held in criminal contempt unless the noncompliance is found beyond a reasonable doubt to have been willful. United States v. Greyhound Corp., 508 F.2d 529, 531 (7th Cir. 1974). In the present case the district court expressly declined to find Curry's noncompliance willful. A ruling of criminal contempt would thus have been inappropriate.
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