McCormick v. United States

FERREN, Associate Judge:

Judge Walton summarily convicted appellant of criminal contempt under Super.Ct.Crim.R. 42(a) (1993) for angrily pointing his finger at the judge as appellant left the courtroom after witnessing a sentencing of a Mend or relative. The judge sentenced appellant to 90 days in jail. Appellant contends that, because the summary conviction and sentencing under Rule 42(a) were not immediately necessary to vindicate the trial court’s authority, the judge violated appellant’s constitutional right to due process. In addition, appellant contends that the judge’s failure to recuse…