Baugh v. Commonwealth

David P. Baugh, an attorney licensed to practice in Virginia, was summarily convicted of contempt by a trial judge in the general district court for violating Code § 18.2-456 and sentenced to ten days in jail. Neither the trial judge’s certificate nor the circuit judge’s order affirming the conviction recites the specific provision of Code § 18.2-456 that Baugh was convicted of violating. Based upon the circuit judge’s finding “that [Baugh’s] behavior in the presence of the Court was such that it did obstruct the administration of justice,” we must conclude that the conviction was based upon…