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Harlem in Disorder: A Spatial History of How Racial Violence Changed in 1935

"Freed on Riot Charge," New York Amsterdam News, April 6, 1935, 14.

In the New York Amsterdam News

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Released (27) Twenty-seven of those prosecuted were released at some point in the legal process, just over one in four of those whose for whom the outcome is known. An additional man, Hashi Mohammed, was released on one of the charges made against him but convicted on a second charge. An additional three individuals were released without being taken to court, as likely were another ten arrested for looting whose police records record an unknown disposition. (Not included in this total is Patrolman John McInerney, who the grand jury twice decided not to charge for shooting and killing Lloyd Hobbs).

Individuals released by the police rather than by the courts had likely been spectators rather than participants in the disorder, arrested when police dispersed crowds, a practice that would also be evident in later disorders in Detroit and Harlem in 1943. So too likely were all but one of those discharged in the magistrates courts. While arrested for a cross-section of types of violence that characterized the disorder, assault, breaking windows and looting, as well as unknown activities, they were all charged with disorderly conduct in court. The variety of acts encompassed by that charge fell between being a bystander and a participant in acts of violence and theft, including "offensive, disorderly, threatening, abusive or insulting language, conduct or behavior," acting to "annoy, disturb, interfere with, obstruct, or be offensive to others," refusing "to move on when ordered by the police," and causing a crowd to collect. If the change in charge indicated police lacked evidence to charge them with the offense for which they had been arrested, the decision to nonetheless proceed with their prosecution indicated some evidence they had been more than bystanders. Or it could be that police asserted that just being in the crowds around acts of violence indicated an intention to participate in violence, amounting to "disorderly" conduct or behavior.

The release of individuals charged with disorderly conduct could result from police having grabbed members of a crowd who they could not associate at all with acts for which they had been arrested, as appeared to be the case with Viola Woods, who the magistrate released because of a "lack of evidence" according to a report in the New York Amsterdam News. He was likely encouraged in that decision by a lawyer representing Woods, one of a small number of recorded as representing those arrested in the disorder. (She was the only one of the six Black women prosecuted to be acquitted.) While there were no newspaper reports of the other discharges — in fact the white press generally only mentioned convictions or the progress of prosecutions to superior courts —another of those released, Aubrey Patterson, also had a lawyer. However, most of these released had been arrested in two groups, suggesting that the alleged incidents in those cases might not have happened at all. One set of arrests occurred after what several newspapers initially reported as a sniper attack on police, which led officers to target a group of Black men standing in a doorway. They did try to avoid being taken into custody, going into the building, on to the roof, and in one case unsuccessfully trying to jump to a neighboring rooftop. However, no weapons were recovered from the four arrested men, Charles Alston, Albert Yerber, Edward Loper, and Ernest Johnson, and no evidence was found of any gun shots. A note in the docket book that the form of disorderly conduct charged was acting to "annoy" suggests that police nonetheless alleged the men were responsible for the noise to which officers reacted. Their discharge indicated that Magistrate Ford was unconvinced. Police arrested three other men, Jacob Bonaparte, Oscar Austin, and Sam Nicholas, for allegedly looting the same store store. While it is possible that police could have apprehended multiple members of a crowd at the scene without any of those men being associated with either damaging the store or taking merchandise, it seems more likely that the attack on the store did not take place at the time when the men were arrested.

The release of a proportion of those police charged with disorderly conduct was not out of the ordinary; after the disorder, however, the proportion released appeared to be different. In the prior week, magistrates released forty-four of the eighty men and women charged with disorderly conduct in the Harlem court, including a group of thirty on March 15 and another group of nine on March 18, suggesting a police practice of arresting members of crowds to get them off the street. In comparison, those released after the disorder having been charged with disorderly conduct represented a smaller proportion, ten of forty-nine men and women. Perhaps unsurprisingly, magistrates appeared to be more willing to consider those on Harlem's streets to be disorderly rather than spectators (even as the sentences imposed in all levels of the courts indicated that judges saw only a limited amount of violence in the actions of those convicted).

The very small proportion of the cases sent to the grand jury that it voted to dismiss, only two of forty-five, suggested a similar willingness to treat those arrested as contributing to the disorder even if police lacked evidence to support the initial charges made against them, particularly when put alongside the high proportion of misdemeanor rather than felony charges for which they voted. A misdemeanor charge was not what prosecutors sought when they sent a case to the grand jury. Individuals could be sent for trial on misdemeanor charges direct from the magistrates court: twenty of those arrested in the disorder were dealt with in that way. In not charging twenty-two individuals referred to them with a felony, the grand jury determined that police had not gathered evidence to support the initial charge. But rather then dismiss the charges entirely and release those individuals, they instead reduced the charges, sending them to the Court of Special Sessions for prosecution as nonetheless involved in the disorder. One case that the grand jury did dismiss involved a form of evidence unusual in the prosecutions after the disorder. Clifford Mitchell had been arrested the evening after the disorder, in his home, for looting. While there was no mention of how police came to make the arrest, items found in Mitchell's home that Louis Levy identified as coming from his store were identified in the legal record as evidence against him. There is no mention of what those items were and how police established that they had not been obtained at a time other than the disorder. (Daughty Shavos, arrested in similar circumstances, was sent to the Court of Special Sessions). Such arrests would be a significant part of the police response to the racial disorder in Harlem in 1943, when 109 individuals, twenty percent of those arrested, were charged with receiving stolen goods. The second case dismissed by the grand jury involved Bernard Smith, charged with riot. Given that an additional charge of breaking windows had been reduced to disorderly conduct and punished by a sentence of only five days in the Workhouse or a fine of $25, it seems likely that police did not have compelling evidence that Smith had not been responsible for crowds breaking windows as they alleged.

The ten individuals released in the Court of Special Sessions had been arrested for inciting riot, looting, or possession of a weapon. The first group were atypical of those arrested in the disorder, the Young Liberators Daniel Miller, Sam Jameson, Murray Samuels, and Claudio Viabolo, three white men, and one Black man, alleged by the District Attorney Dodge and the Hearst newspapers to have started the disorder. ILD lawyers represented the four men. By the time they went to trial, represented by ILD lawyers, witnesses in the public hearings of the MCCH had debunked the claims they were responsible. The four men acquitted of looting included one about who there are no details and one apprehended in a crowd around a store who police likely could not link to its looting. The two remaining men, like Mitchell, police arrested away from the businesses they allegedly looted, although during the disorder not the next day. James Williams had been represented by a lawyer in the Magistrates court, so may have had a better defense than most arrested during the disorder; the other, Jean Jacquelin, was a white man. While five white men in all were released, almost two-thirds of those arrested, that the three Communists are included in that group weighs against that indicating that the courts showed leniency towards white defendants. Hashi Mohammed's release after being charged with possession of a weapon, a knife, came after he had been convicted of disorderly conduct in the Washington Heights Magistrates court having been arrested for breaking windows. He was injured, likely by police during his arrest, and the weapon possession charge may have been made to justify that violence.

Five men were acquitted in the Court of General Sessions, three arrested for looting at the direction of the judge, and two arrested for assaulting white men by juries. Milton Ackerman and Raymond Easley had their indictments dismissed, suggesting a lack of evidence of the charges. Easley had been part of a crowd in front of a cigar store when the windows were smashed, one of two men arrested by police, and charged with taking cigars. The dismissal indicated police could not prove that theft. Few details exist of the charges against Ackerman other than that he had taken merchandise with little value. Joseph Moore, acquitted at the direction of the judge, was arrested on the Third Avenue bridge, on the way to the Bronx, with unspecified merchandise allegedly taken from a Harlem store. The likeliest cause of Moore's release was a lack of evidence that whatever was found in his possession had been stolen.

In acquitting Paul Boyett and Isaac Daniels, juries decided that police had arrested the wrong members of crowds on the streets. Boyett had been among those drawn to investigate the attack on Timothy Murphy, the most widely reported assault on a white man during the disorder, and he scattered with that crowd when a police car drove up. It was being hit by a bullet that Patrolman George Conn fired at the crowd that led to Boyett being singled out, pursued, and arrested. The prominent Black lawyer, William T. Andrews, representing Boyett clearly exposed the lack of evidence that he had been one of those who assaulted Murphy. In the case of Isaac Daniels, it appears to have been Herman Young, the storeowner injured when someone threw a rock that broke the glass in the door to his store, who was responsible for the wrong man being arrested. Daniels was arrested at Harlem Hospital, after Young saw him while being treated. However, Daniels wife said he was home at the time of the attack, having gone to the movies, and later went out to get cigarettes. None of the sources mention how he came by the injuries, contusions on his left arm, that he was having treated at Harlem Hospital when Young claimed to recognize him.
Completing the legal process (March 28-November) A week after those arrested during the disorder began to appear in the Harlem and Washington Heights Magistrates court, the prosecutions of approximately sixty-four of those men and women had been completed. It would take almost eight months for judges and juries to come to decisions regarding the fate of the remaining forty-nine men and two women. Those proceedings went largely unreported, further diminishing the violence in the picture of the disorder presented by the press. After the New York Times, New York Evening Journal, New York American, and New York Amsterdam News published stories about cases in the Harlem court and Court of General Sessions on March 28, only four other trials were mentioned in the press. The Daily Worker published stories on the trials of Communist Party members or at least those represented by ILD lawyers: the only story about Joseph Moore and one of only two stories about the trial of Daniel Miller and the three Young Liberators in the Court of Special Sessions. The involvement of ILD lawyers and the verdict in their favor made those trials an obvious vehicle for promoting the Communist Party. It is less clear why the other story about the later trial was published in the Black newspaper the New York Amsterdam News. It also published the one story about the trial of Paul Boyett. Boyett was acquitted of assaulting a white man, suggesting that the editors of the Black newspaper were concerned to give attention to outcomes that discredited the idea that the disorder had been a race riot. The story mentioned only Boyett's defense, so literally kept the alleged assault out of the story. The New York Amsterdam News may have also published the story about the trial involving the Communists because the same publications and individuals who had sought to blame them had also cast the disorder as a race riot. The New York Times rather than either of those publications reported the one other case that attracted attention, the trial of James Hughes. Unaffiliated with the Communist Party and found guilty of throwing a rock that hit a police officer, that case did not align with the apparent agendas of those publications. Why the New York Times reported the trial is not clear; it was the only legal proceeding related to the disorder that the newspaper reported after March 28.

Unreported, the final eight of those arrested during the disorder trickled out of the Magistrates courts over the next three weeks as police completed investigations. Magistrate Ford disposed of the last of those arrested in the jurisdiction of the Washington Heights court on April 9, when Charles Alston was sufficiently recovered from injuries suffered fleeing police to appear and have the assault charges against him dismissed, the same outcome as the three men arrested with him. Magistrate Renaud did not dispose of the last case before him in the Harlem court for nearly two more weeks. The extended police investigation of that case likely was a result of the defendant, Frank Wells, having ties to the Communist Party. However, police did not produce evidence to support the allegation that Wells had broken the window of a store on 125th Street, resulting in the charge against him being reduced to disorderly conduct. On April 20, a month after the first of those arrested in the disorder appeared in his court, Renaud convicted Wells and sent him to the Workhouse for 30 days.

The grand jury continued to vote for charges in all of the final twenty cases involving individuals arrested during the riot presented to them, as they had with almost all the previous cases, but those decisions did not signal that they had been presented evidence of significant violence or that police had apprehended those most responsible for the disorder. The grand jury sent only seventeen of those arrested in the disorder to the Court of General Sessions charged with felonies, and only one of the final twenty cases. All the remainder, and just over half of all the cases related to the disorder, the grand jury sent to be tried on lesser misdemeanor charges in the Court of Special Sessions. The last case involving an arrest during the disorder presented to the grand jury was the one case presented after March 27 for which the grand jury voted an indictment. On April 23 it charged Paul Boyett with assaulting a white man. The grand also twice heard evidence about the killing of sixteen-year-old Lloyd Hobbs by Patrolman John McInerney, first on April 10, and then again on June 10, after the MCCH found additional witnesses. On both occasions the all-white grand jury dismissed the case, finding the white officer justified in killing of the Black boy.

The combination of cases sent from the grand jury and those sent directly to the court by magistrates made trials in the Court of Special Sessions the proceeding in which most of the remaining cases were decided. Those trials received almost no attention from the press even as the panel of three magistrates who presided convicted three out of every four of those who appeared. Eight of the nine men not convicted appeared in the court in the weeks after March 27. A single trial, of the four Communists, produced half of those acquittals, two months after the disorder, on June 21. A further five months later, the final trial did result in a conviction, of the other white man arrested at the beginning of the disorder, Harry Gordon, for assaulting a police officer.

Convictions were almost as often the outcome for those those sent to the Court of General Sessions as for those sent to the Court of Special Sessions, but the process was different. All but one of those convicted accepted the plea bargains that prosecutors offered as a standard practice at this time, eight after March 27 following Carl Jones, Hezekiah Wright, Joseph Wade, and Thomas Jackson earlier. They pled guilty to a lesser offense, which for all but one of those arrested was a misdemeanor, which effectively erased the distinction between being convicted in the Court of General Sessions and in the Court of Special Sessions. Two other men were released without trial, Milton Ackerman and Raymond Easley. All five of the men put on trial in this court appeared more than a week after the disorder, reflecting the multiple steps involved in prosecuting a felony. Only three had their guilt decided by a jury. The judge directed the acquittal of Joseph Moore, while Arnold Ford pled guilty during his trial. Just one man was convicted by a jury, James Hughes, but he too was found guilty of only a misdemeanor. Despite being charged with assaulting white men, both Isaac Daniels and Paul Boyett were acquitted. Boyett was the last of those arrested in the disorder to appear in the Court of General Sessions, on May 29. That left Edward Larry as the only individual convicted of a felony, having pled guilty to attempted grand larceny rather than face trial on a charge of robbery. While he was only person charged with that offense, his previous felony conviction had more to do with the outcome of this prosecution than what he allegedly had done in the disorder. That the most severe legal response should be to an offense as unrepresentative of the events of the disorder as robbery—one committed by a defendant with a criminal record that set him apart from the others arrested—demonstrated the extent to which prosecutions in the legal system did not reflect the events of the disorder.
Breaking windows in the courts (20) Seventeen men and three women who were arrested for breaking windows appeared in court. Prosecutors did not charge seven of those individuals with the offense for which they had been arrested, but instead with disorderly conduct. An additional three men and one woman — David Terry, Julius Hightower, Warren Johnson, and Louise Brown — had the charge against them reduced to disorderly conduct after their initial appearance in court. The proportion of those arrested for breaking windows who faced that lesser charge (11 of 20, 55%) fell between that of those arrested for assault (8 of 13, 62%) and than of those arrested for looting (12 of 50, 20%) — although given that the basis for the arrest of sixteen of those charged with disorderly conduct (32%) is unknown that pattern has to be be considered uncertain. If the change in charge indicated police lacked evidence to charge those individuals with breaking windows, the decision to nonetheless proceed with their prosecution indicated some evidence that associated them with the disorder. The variety of acts encompassed by disorderly conduct fell between being a bystander and a participant in acts of violence and theft, including "offensive, disorderly, threatening, abusive or insulting language, conduct or behavior," acting to "annoy, disturb, interfere with, obstruct, or be offensive to others," refusing "to move on when ordered by the police," and causing a crowd to collect. Possible scenarios might involve acting in a way that police interpreted as indicating an intention to participate in violence, amounting to "disorderly" conduct or behavior - most likely by being parts of crowds in the vicinity when store windows were broken. Magistrates found guilty all but one of those charged with disorderly conduct after being arrested for breaking windows. Viola Woods, one of the few defendants represented by a lawyer, "was freed for lack of evidence" according to a story in the New York Amsterdam News. Among those convicted was another Black woman, Louise Brown, and the one white man arrested for breaking windows, Leo Smith.

The charge brought against individuals who were prosecuted for breaking windows was malicious mischief. That offense punished unlawful and wilful destruction or injury to property. It was a felony if the damage amounted to more than $250. Magistrates transferred eight men and one woman who faced that charge to the Court of Special Sessions for trial; they sent no one charged with malicious mischief to the grand jury. Those outcomes reflected that the value of windows, particularly those of the scale found in the small businesses on Harlem's avenues, was far less than $250. In the case of William Jones, prosecutors had originally charged him with a felony, which was reduced to a misdemeanor after investigation.

Judges in the Court of Special Session convicted five of those charged with malicious mischief while acquitting only one, Henry Stewart (the outcome of the other three trials is unknown). While William Jones had his sentence suspended, the other three Black men, Charles Wright, William Norris, and David Bragg, received sentences of three months in the workhouse, among the longer sentences imposed on those arrested during the disorder. Rose Murrell received a shorter term of only one month in the workhouse. While her gender was the most obvious explanation for that difference, it may be that Murrell caused less damage than the men. No details of the cost of replacing the windows are provided in any of these cases.

In any case, Murrell was the only one of the three Black women arrested for breaking windows convicted of that offense. That Louise Brown was found guilty of disorderly conduct indicated only that the magistrate was convinced that she had been part of a crowd around an attack on a store, whereas the acquittal of Viola Woods removed her further from the violence, casting her as a bystander.

Similarly, the conviction of Leo Smith, the white man arrested for breaking windows, for disorderly conduct placed him at a distance from damage to a store, without explaining his presence in the crowds on the street.
Viola Woods arrested Officer St. Louis of the 28th Precinct arrested Viola Woods, a twenty-eight-year-old Black woman, for allegedly smashing the window of a vacant store at 2314 8th Avenue with an umbrella sometime during the disorder. There was no information on when during the disorder the arrest took place. The most likely time would be around 10:00 PM, when the disorder intensified and many of those at the nearby intersection of 8th Avenue and 125th Street began to move up and down the avenue. Only a New York Amsterdam News story identified the store as vacant; a list in the New York American and stories in the Home News and New York Times provided only the address. The vacant store was in the block between 125th and 124th Streets, where four other stores had windows broken, including two other empty stores at 2320 8th Avenue and 2324 8th Avenue, the Arrow Sales 5 & 10c store at 2318 8th Avenue and Andy's Florist on the southeast corner of 125th Street. Those other damaged stores were all included in a list of those with broken windows made by a reporter for La Prensa who walked west along 125th Street and and up and down 8th Avenue a block north and south of the intersection on the day after the disorder. It was possible the store whose window Woods allegedly broke was not on that list because it suffered only minor damage; the La Prensa reporter concluded their list by noting they had not included others as they had only suffered minor damage ("y otras mas que por ser los danos ocasionados relativamente pequeños no creimus de interes catalogar entre los establecimientos ya mencionados").

Woods name was misrecorded in the 28th Precinct police blotter as Viola Williams, a mistake repeated in the list of those arrested during the disorder published in in the Atlanta World, Afro-American, and Norfolk Journal and Guide, and the list in the New York Evening Journal. The New York American misreported Woods' name as Loyola Williams. Another woman named Loyola Williams was arrested during the disorder and charged with burglary. Both women were recorded as being twenty-eight-years of age and living at 301 West 130th Street. While these overlapping details might indicate the reports refer to a single woman, both Loyola Williams and Viola Williams [Woods] appear in the list published in the Atlanta World, Afro-American, and Norfolk Journal and Guide, and the list in the New York Evening Journal, with Viola Williams [Woods] charged with malicious mischief, an offense involving the destruction of property used in the prosecution of those alleged to have broken windows during the disorder. That is the charge recorded in the 28th Precinct police blotter, with a note reading "Broke window with umbrella." However, when that woman appeared in the Harlem Magistrates Court, the docket book and stories about her two appearances in court in the New York Amsterdam News, Home News, and New York Times recorded her name as Viola Woods.

When Woods appeared in the Harlem Magistrates Court on March 20, the charge against her was disorderly conduct. The change from malicious mischief indicated police did not have evidence that she had broken the window, but only that she had been in the crowds in the area of the attack. Disorderly conduct was a charge that the magistrate could adjudicate, unlike misdemeanor and felony charges that required referral to other courts. Magistrate Renaud ordered Woods held on bail of $100, a court appearance reported in the Home News. Unusually, she was represented by a lawyer, future alderman Eustace Dench of 207 West 125th Street. Dench was one of several prominent members of the Harlem Lawyers Association who represented those arrested during the disorder. When Woods returned to the court on March 28, Magistrate Ford discharged her. The New York Amsterdam News reported that she "was freed for lack of evidence." The New York Times story simply reported that she had been discharged, the outcome recorded in the 28th Precinct police blotter. That outcome suggests Woods was not part of a crowd that clashed with police but likely simply a bystander.

The woman arrested may be the woman named Viola Woods a census enumerator found at 123 West 133rd Street on April 16, 1940. She was the same age and had been in Harlem in 1935. Born in South Carolina, in Hilton Head, she gave birth to a son, William, in 1923, and a second son, Samuel, in 1925, according to their draft registrations. At that time her last name was Bligen. She arrived in Harlem sometime between 1925 and 1930, when she was recorded in the census living at 255 West 143rd Street, with a cousin, working as a domestic servant (both her sons are recorded as living with their father, William Bligen and his wife in Hilton Head until at least 1940). In 1931, she married Chester Woods, a West Indian longshoreman. At the time of the 1940 census, they had four children, aged between ten and two years. When her sons William and Samuel registered for the draft in 1942, Viola Woods was living at 49 West 133rd Street.
Loyola Williams arrested Sometime during the disorder, Loyola Williams, a twenty-eight-year-old Black woman who lived at 301 West 130th Street, was arrested and charged with burglary. Williams' name appeared among those charged with burglary in the list published in the Atlanta World, Afro-American, and Norfolk Journal and Guide and the list in the New York Evening Journal, which also included her age, race, and address. However, Williams did not appear in 28th Precinct police blotter, the 32nd Precinct police reports, or the docket book of either Magistrates court or any newspaper stories, and there was no evidence of the location of the business that she allegedly looted. That was also the case with nine men who appeared only in the list published in the Atlanta World, Afro-American, and Norfolk Journal and Guide. Their failure to appear in court could mean that police questioned and released them the next day.

In the case of Loyola Williams, it was also possible that whoever compiled the list had confused her with another Black woman arrested during the disorder, Viola Woods, who was identified as Viola Williams in several sources. Both women were recorded as being twenty-eight-years of age and living at 301 West 130th Street. However, both Loyola Williams and Viola Williams appeared in the list published in Atlanta World, Afro-American, and Norfolk Journal and Guide, and the list in the New York Evening Journal, with Viola Williams charged with malicious mischief. Viola Williams also appeared in the 28th Precinct police blotter with the same age and address, and a note that recorded her alleged offense as using her umbrella to break a store window. However, when that woman appeared in the Harlem Magistrates Court, the docket book and stories about her two appearances in court in the New York Amsterdam News, Home News, and New York Times recorded her name as Viola Woods.
Vacant store windows broken (2314 8th Avenue) The windows of a vacant store at 2314 8th Avenue were broken sometime during the disorder. Smashing glass was reported in the area around 8:00 PM and then again around 9:30 PM. The vacant store was in the block between 125th and 124th Streets, where four other stores had windows broken, including two other empty stores at 2320 8th Avenue and 2324 8th Avenue, the Arrow Sales 5 & 10c store at 2318 8th Avenue, and Andy's Florist on the southeast corner of 125th Street. Those other damaged stores were all included in a list of those with broken windows made by a reporter for La Prensa who walked west along 125th Street and up and down 8th Avenue a block north and south of the intersection on the day after the disorder. It is possible this store was not on that list because it suffered only minor damage; the La Prensa reporter concluded their list by noting they had not included others as they had only suffered minor damage ("y otras mas que por ser los danos ocasionados relativamente pequeños no creimus de interes catalogar entre los establecimientos ya mencionados").

Officer St. Louis of the 28th Precinct arrested Viola Woods, a twenty-eight-year-old Black woman, for allegedly smashing the store window with an umbrella. There is no information on when during the disorder the arrest took place. Only a New York Amsterdam News story identified the store as vacant; a list in the New York American and stories in the Home News and New York Times provided only the address. After being charged with disorderly conduct in the Harlem Magistrates Court on March 20, Woods was ordered held on bail of $100 by Magistrate Renaud. When she was returned to the court on March 28, Magistrate Ford discharged her, the New York Amsterdam News reporting that she "was freed for lack of evidence."

By the second half of 1935, when the MCCH business survey was conducted, a white-owned restaurant was located at 2314 8th Avenue. The Tax Department photograph shows a one-story building constructed after 1935.
In Harlem court on March 28 (2) The New York Amsterdam News published a brief story about Viola Woods' return to the Harlem Magistrates court, under the headline, "Freed on Riot Charge." The story noted that her discharge was due to "lack of evidence." Such an explanation of a decision by a magistrate to release an individual arrested during the disorder was not part of stories about other cases. Woods was also mentioned in a New York Times story that covered legal proceedings involving individuals arrested in the disorder in the grand jury, the Court of General Sessions, and the Harlem court. The story noted her discharge on a charge of disorderly conduct without any explanation. It made no mention of Louis Tonick's case being continued or William Cobb's case being continued in the Washington Heights court.