At past appearances, Amu had attempted to read passages from the Bible and the Q'uran to the court. Prior to Amu's interactions with Judge Brewer in this case, Amu had been before Judge Brewer as counsel in Ibrahim v. Reproductive Genetic Institute, Case No. 09 L 12831, in which Amu had engaged in similar conduct and similarly maligned Judge Brewer. The court's written order entering its finding of direct criminal contempt was not entered until April 27, 2012.