Bethard v. District of Columbia

A trial judge summarily found appellant guilty of criminal contempt under Super.Ct.Crim.R. 42(a) (1993), citing appellant’s “overall disruptive behavior” in the morning while he was waiting in the courtroom for his traffic case to be called, his “state of stupor” throughout the day, and, his repeated attempts “to verbally interrupt the court” when he was called before it in the afternoon. The court sentenced appellant to 30 days in jail. See Court’s Order, Appendix, infra.

On appeal, appellant contends that the evidence did not show his behavior to be sufficiently willful or disruptive to…