State v. Kilbane

The sole issue raised in this appeal is the propriety of the sanction imposed upon appellee for her contemptuous conduct. To resolve this issue the contempt must be reviewed on two levels. Cincinnati v. Cincinnati District Council 51 (1973), 35 Ohio St. 2d 197, certiorari denied (1974), 415 U.S. 994. First, appellee’s conduct must be examined to see if it constituted a direct or indirect contempt. Second, the trial court’s treatment of this matter must be analyzed to ascertain whether appellee was dealt with under that court’s civil or criminal contempt powers.

The trial judge in this cause…