State v. Spainhower

Defendant appeals a judgment imposing a sanction for summary contempt that was entered more than nine months after defendant engaged in the underlying contumacious conduct. He argues that the trial court lacked authority to sanction him for a contempt that was committed in the immediate view and presence of the court after such a lengthy delay.1 We reverse.

On May 19, 2009, defendant was tried by a jury on a charge of harassment. On May 20, the jury returned a guilty verdict. Defendant was upset by the verdict, and he told the court that the verdict was an injustice. The court told defendant…