Sunset Travel, Inc. v. Lovecchio

Defendant, Roberto Lovecchio, was found in contempt of court. He was sentenced to 30 days in jail, but could purge himself and obtain his immediate release by delivering over to Sunset Travel, Inc., one of the plaintiffs, certain airline tickets claimed by Sunset to be its property.

On appeal Lovecchio essentially contends: (1) that he was erroneously found guilty of “direct civil contempt” where, at most, he could be found guilty of “indirect criminal contempt”; (2) that he was erroneously denied his due process rights; and (3) that the 30-day jail sentence sanction was imposed improperly.

We…