In re the Contempt of West

BALEY, Judge.

Proceedings for contempt are governed by Chapter 5 of the General Statutes of North Carolina and are classified as either “direct” or “indirect,” depending upon whether they are committed within or beyond the presence of the court. Galyon v. Stutts, 241 N.C. 120, 84 S.E. 2d 822 (1954); In Re Edison, 15 N.C. App. 354, 190 S.E. 2d 235 (1972); see Snepp, The Law of Contempt in North Carolina, 7 Wake Forest L. Rev. 1.

To constitute direct contempt, the conduct does not have to occur in the courtroom, but “[a] direct contempt consists of words spoken or acts committed in the actual or…