State v. Dugan

Cowlitz County Deputy Prosecutor Christopher T. Mahre appeals from a summary order of contempt. The trial court sanctioned him for asking a criminal defendant a question that, according to the trial judge, was “irrelevant, scandalous, and inflammatory.” Because a trial court may impose a summary contempt sanction pursuant to RCW 7.21.050 only for conduct constituting contempt under RCW 7.21.010, such as violating a court order or behaving in a disorderly, contemptuous, or insolent manner that tends to disrupt or interrupt the proceedings so severely as to warrant immediate sanction, and…