J.D.J. v. State

Because J.D.J. was fifteen minutes late to court, he was found in direct criminal contempt and given five additional days in secure detention.1 Willfulness is required for an individual to be detained or incarcerated for direct criminal contempt. Because the unrebutted facts demonstrate that J.D.J. did not have control over his arrival time, his tardiness could not have been willful; therefore, we reverse. Further, fundamental error is present when procedural rules governing due process for direct criminal contempt proceedings are not scrupulously followed. Florida Rule of Juvenile Procedure…