Cases by Issue - Contempt of Court

United Mineworkers of America v. Bagwell

Mon, 05 Jan 2009 16:23:49 +0000

Case Basics

Docket No.

92-1625

Petitioner

United Mineworkers of America

Respondent

Bagwell

Heard By

Rehnquist Court (1993-1994)

Decided By

Rehnquist Court (1993-1994)

Opinion

512 U.S. 821 (1994)

Argued

Monday, November 29, 1993

Decided

Thursday, June 30, 1994

Advocates

Laurence E. Gold (on behalf of the Petitioners)

Paul Bender (as amicus curiae, supporting the Respondents)

John G. Roberts, Jr. (on behalf of the Respondents)

Facts of the Case

A Virginia trial court warned the United Mine Workers of America union to refrain from certain unlawful strike-related activities. Over the course of the next few months, finding that the union had disregarded the warning more than 400 times, the court fined them more than $64 million in what it termed civil fines, payable to the state of Virginia. After the strike was settled the court refused to cancel the fines, despite the fact that the strike settlement had called for their cancellation. The Court ruled that the fines were payable to the state, not the mining company, and that the settlement could not therefore cancel them. The Virginia Court of Appeals reversed, canceling the fines in accordance with the settlement agreement, but on further appeal the Supreme Court of Virginia reinstated the fines. It held that the union had been warned in advance and could have avoided the fines, meaning that it controlled its own destiny. The fines were therefore not criminal (imposing criminal fines would have required a jury trial) but instead civil, as the trial court had argued, because they were intended to maintain order and respect for the courts by encouraging compliance with a court order.

Question

Were the fines assessed against the United Mine Workers of America union, amounting to more than $64 million, criminal or civil in nature?

Conclusion

Decision: 9 votes for United Mineworkers of America, 0 vote(s) against
Legal provision:

The fines were criminal in nature. The Supreme Court unanimously held that they had been intended to punish the union, not merely to maintain order or respect for the judiciary, and that the union was therefore entitled to the heightened protections of a criminal proceeding, such as a jury trial. Justice Harry Blackmun in the opinion of the Court, wrote, "The union's sanctionable conduct did not not occur in the court's presence or otherwise implicate the court's ability to maintain order and adjudicate the proceedings before it. ... Instead, the Virginia trial court levied contempt fines for widespread, ongoing, out-of-court violations of a complex injunction. In so doing, the court effectively policed petitioner's compliance with an entire code of conduct that the court itself had imposed. ... Under such circumstances, disinterested factfinding and evenhanded adjudication were essential, and petitioners were entitled to a criminal jury trial."

Hicks v. Feiock

Mon, 05 Jan 2009 17:25:36 +0000

Case Basics

Docket No.

86-787

Petitioner

Hicks

Petitioner Type

Petitioner

Respondent

Feiock

Respondent Type

Respondent

Heard By

Rehnquist Court (1987-1988)

Decided By

Rehnquist Court (1988-1990)

Opinion

485 U.S. 624 (1988)

Argued

Tuesday, December 1, 1987

Decided

Wednesday, April 27, 1988

Advocates

Michael R. Capizzi (on behalf of the petitioner)

Richard Lynn Schwartzberg (on behalf of the respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Hicks, 3 vote(s) against
Legal provision: Due Process

None

Young v. U.S. Ex Rel. Vuitton Et Fils S. A.

Mon, 05 Jan 2009 17:33:27 +0000

Case Basics

Docket No.

85-1329

Petitioner

Young

Petitioner Type

Petitioner

Respondent

U.S. Ex Rel. Vuitton Et Fils S. A.

Respondent Type

Respondent

Consolidation

No. 85-6207

Heard By

Rehnquist Court (1986-1987)

Decided By

Rehnquist Court (1986-1987)

Opinion

481 U.S. 787 (1987)

Argued

Tuesday, January 13, 1987

Decided

Tuesday, May 26, 1987

Advocates

James A. Cohen (on behalf of the Petitioners)

J. Joseph Bainton (on behalf of Respondents)

William C. Bryson (as amicus curiae in support of Petitioners)

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Young, 4 vote(s) against
Legal provision: Federal Rules of Criminal Procedure (or relevant rules of a circuit court)

None

United States v. Rylander

Mon, 05 Jan 2009 17:33:19 +0000

Case Basics

Docket No.

81-1120

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Rylander

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

460 U.S. 752 (1983)

Argued

Tuesday, January 18, 1983

Decided

Tuesday, April 19, 1983

Advocates

Joseph H. Harbison, III (on behalf of the Respondent)

Lawrence G. Wallace (on behalf of the Petitioners)

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for United States, 1 vote(s) against
Legal provision: Self-Incrimination

None

Muniz v. Hoffman

Mon, 05 Jan 2009 16:33:06 +0000

Case Basics

Docket No.

73-1924

Petitioner

Muniz

Petitioner Type

Petitioner

Respondent

Hoffman

Respondent Type

Respondent

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

422 U.S. 454 (1975)

Argued

Monday, March 24, 1975

Decided

Wednesday, June 25, 1975

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Hoffman, 4 vote(s) against
Legal provision: Right to Trial By Jury

None

United States v. Wilson

Mon, 05 Jan 2009 16:33:24 +0000

Case Basics

Docket No.

73-1162

Petitioner

United States

Respondent

Wilson

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

421 U.S. 309 (1975)

Argued

Tuesday, December 17, 1974

Decided

Monday, May 19, 1975

Advocates

Gerald P. Norton (argued the cause for the United States)

Sheila Ginsberg Riesel (argued the cause for the respondent Wilson)

John S. Martin, Jr. (argued the cause for the respondent Bryan)

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for United States, 3 vote(s) against
Legal provision: Federal Rules of Criminal Procedure (or relevant rules of a circuit court)

None

Maness v. Meyers

Mon, 05 Jan 2009 16:33:40 +0000

Case Basics

Docket No.

73-689

Petitioner

Maness

Petitioner Type

Petitioner

Respondent

Meyers

Respondent Type

Respondent

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

419 U.S. 449 (1975)

Argued

Tuesday, October 22, 1974

Decided

Wednesday, January 15, 1975

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Maness, 0 vote(s) against
Legal provision:

None

Codispoti v. Pennsylvania

Mon, 05 Jan 2009 17:09:56 +0000

Case Basics

Docket No.

73-5615

Petitioner

Codispoti

Petitioner Type

Petitioner

Respondent

Pennsylvania

Respondent Type

Respondent

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

418 U.S. 506 (1974)

Argued

Monday, March 25, 1974

Decided

Wednesday, June 26, 1974

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Codispoti, 4 vote(s) against
Legal provision: Right to Trial By Jury

None

Taylor v. Hayes

Mon, 05 Jan 2009 17:09:54 +0000

Case Basics

Docket No.

73-473

Petitioner

Taylor

Petitioner Type

Petitioner

Respondent

Hayes

Respondent Type

Respondent

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

418 U.S. 488 (1974)

Argued

Monday, March 18, 1974

Decided

Wednesday, June 26, 1974

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Taylor, 1 vote(s) against
Legal provision: Due Process

None

Johnson v. Mississippi

Mon, 05 Jan 2009 17:18:55 +0000

Case Basics

Docket No.

5485

Petitioner

Johnson

Petitioner Type

Petitioner

Respondent

Mississippi

Respondent Type

Respondent

Heard By

Burger Court (1970-1971)

Decided By

Burger Court (1970-1971)

Opinion

403 U.S. 212 (1971)

Argued

Wednesday, April 21, 1971

Decided

Monday, June 7, 1971

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Johnson, 0 vote(s) against
Legal provision: Due Process

None

Mayberry v. Pennsylvania

Mon, 05 Jan 2009 17:19:05 +0000

Case Basics

Docket No.

121

Petitioner

Mayberry

Petitioner Type

Petitioner

Respondent

Pennsylvania

Respondent Type

Respondent

Heard By

Burger Court (1970-1971)

Decided By

Burger Court (1970-1971)

Opinion

400 U.S. 455 (1971)

Argued

Thursday, December 17, 1970

Decided

Wednesday, January 20, 1971

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Mayberry, 0 vote(s) against
Legal provision: Due Process

None

In Re Spencer

Mon, 05 Jan 2009 17:39:00 +0000

Case Basics

Docket No.

513

Petitioner Type

Appellee

Appellant

In Re Spencer

Respondent Type

Appellant

Heard By

Burger Court (1969-1970)

Decided By

Burger Court (1969-1970)

Opinion

397 U.S. 817 (1970)

Argued

Tuesday, April 28, 1970

Decided

Monday, May 4, 1970

Facts of the Case

None

Question

None

Conclusion

Decision: 4 votes for , 4 vote(s) against
Legal provision:

None

Frank v. United States

Mon, 05 Jan 2009 17:39:28 +0000

Case Basics

Docket No.

200

Petitioner

Frank

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Warren Court (1967-1969)

Decided By

Warren Court (1967-1969)

Opinion

395 U.S. 147 (1969)

Argued

Thursday, December 12, 1968

Decided

Monday, May 19, 1969

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for United States, 3 vote(s) against
Legal provision:

None

Bloom v. Illinois

Mon, 05 Jan 2009 17:41:13 +0000

Case Basics

Docket No.

Petitioner

Bloom

Respondent

Illinois

Heard By

Warren Court (1967-1969)

Decided By

Warren Court (1967-1969)

Opinion

391 U.S. 194 (1968)

Argued

January 16-17, 1968

Decided

Monday, May 20, 1968

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Bloom, 2 vote(s) against
Legal provision: Right to Trial By Jury

None

Walker v. Birmingham

Mon, 20 Jun 2011 04:06:01 +0000

Location

Birmingham City Council

710 North 20th Street Birmingham AL 35203

Birmingham, AL 35203

United States

33° 31' 12.0936" N, 86° 48' 39.1284" W

See map: Google Maps

Case Basics

Docket No.

249

Petitioner

Walker

Respondent

Birmingham

Heard By

Warren Court (1965-1967)

Decided By

Warren Court (1965-1967)

Opinion

388 U.S. 307 (1967)

Argued

March 13-14, 1967

Decided

Monday, June 12, 1967

Advocates

Louis F. Claiborne (By special leave of the Court, argued the cause for the United States, as amicus curiae, urging reversal)

J. M. Breckenridge (Argued the cause for the respondent)

Earl McBee (Argued the cause for the respondent)

Jack Greenberg (Argued the cause for the petitioners)

Facts of the Case

Civil rights activists who planned to march on Good Friday and Easter were denied parade permits from the city. When they indicated their intention to march anyway, Birmingham obtained an injunction from a state court which ordered them to refrain from demonstrating. Marchers who defied the order, including Martin Luther King, Jr. and Ralph Abernathy, were arrested.

Question

Did the injunction violate the First Amendment?

Conclusion

Decision: 5 votes for Birmingham, 4 vote(s) against
Legal provision:

The Court upheld the arrests since Walker failed to use proper judicial procedures to test the injunction's validity. Even though, Justice Stewart admitted, the injunction seemed broad and vague, and the marchers may not have enjoyed due process when applying for the permit originally, simply disobeying the injunction was illegitimate as "no man can be judge in his own case . . . however righteous his motives."

Cheff v. Schnackenberg

Mon, 05 Jan 2009 17:42:40 +0000

Case Basics

Docket No.

Petitioner

Cheff

Petitioner Type

Petitioner

Respondent

Schnackenberg

Respondent Type

Respondent

Heard By

Warren Court (1965-1967)

Decided By

Warren Court (1965-1967)

Opinion

384 U.S. 373 (1966)

Argued

Thursday, March 3, 1966

Decided

Monday, June 6, 1966

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Schnackenberg, 2 vote(s) against
Legal provision: Right to Trial By Jury

None

Shillitani v. United States

Mon, 05 Jan 2009 17:42:48 +0000

Case Basics

Docket No.

412

Petitioner

Shillitani

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Consolidation

No. 442

Heard By

Warren Court (1965-1967)

Decided By

Warren Court (1965-1967)

Opinion

384 U.S. 364 (1966)

Argued

Wednesday, March 2, 1966

Decided

Monday, June 6, 1966

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Shillitani, 1 vote(s) against
Legal provision:

None

Harris v. United States

Mon, 05 Jan 2009 17:42:51 +0000

Case Basics

Docket No.

Petitioner

Harris

Respondent

United States

Heard By

Warren Court (1965-1967)

Decided By

Warren Court (1965-1967)

Opinion

382 U.S. 162 (1965)

Argued

October 11-12, 1965

Decided

Monday, December 6, 1965

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Harris, 4 vote(s) against
Legal provision: Federal Rules of Criminal Procedure (or relevant rules of a circuit court)

None

Holt v. Virginia

Mon, 05 Jan 2009 17:34:23 +0000

Case Basics

Docket No.

464

Petitioner

Holt

Petitioner Type

Petitioner

Respondent

Virginia

Respondent Type

Respondent

Heard By

Warren Court (1962-1965)

Decided By

Warren Court (1962-1965)

Opinion

381 U.S. 131 (1965)

Argued

Tuesday, April 27, 1965

Decided

Monday, May 17, 1965

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Holt, 1 vote(s) against
Legal provision: Due Process

None

Ungar v. Sarafite

Mon, 05 Jan 2009 17:37:36 +0000

Case Basics

Docket No.

167

Petitioner

Ungar

Petitioner Type

Petitioner

Respondent

Sarafite

Respondent Type

Respondent

Heard By

Warren Court (1962-1965)

Decided By

Warren Court (1962-1965)

Opinion

376 U.S. 575 (1964)

Argued

Monday, February 24, 1964

Decided

Monday, March 30, 1964

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Sarafite, 3 vote(s) against
Legal provision:

None

United States v. Barnett

Mon, 05 Jan 2009 17:34:40 +0000

Case Basics

Docket No.

107

Petitioner

Barnett

Respondent

United States

Heard By

Warren Court (1962-1965)

Decided By

Warren Court (1962-1965)

Opinion

376 U.S. 681 (1964)

Argued

October 21-22, 1963

Decided

Monday, April 6, 1964

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for United States, 4 vote(s) against
Legal provision: 18 U.S.C. 402

None

In Re Mcconnell

Mon, 05 Jan 2009 17:42:01 +0000

Case Basics

Docket No.

498

Petitioner

In Re Mcconnell

Petitioner Type

Petitioner

Respondent Type

Respondent

Heard By

Warren Court (1962)

Decided By

Warren Court (1962)

Opinion

370 U.S. 230 (1962)

Argued

Tuesday, April 10, 1962

Decided

Monday, June 18, 1962

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for In Re Mcconnell, 2 vote(s) against
Legal provision: 18 U.S.C. 401

None

Levine v. United States

Mon, 05 Jan 2009 16:30:38 +0000

Case Basics

Docket No.

164

Petitioner

Levine

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Warren Court (1958-1962)

Decided By

Warren Court (1958-1962)

Opinion

362 U.S. 610 (1960)

Argued

Tuesday, March 22, 1960

Decided

Monday, May 23, 1960

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for United States, 4 vote(s) against
Legal provision: Amendment 6: Other Sixth Amendment Provisions

None

Brown v. United States

Mon, 05 Jan 2009 16:29:24 +0000

Case Basics

Docket No.

Petitioner

Brown

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Warren Court (1958-1962)

Decided By

Warren Court (1958-1962)

Opinion

359 U.S. 41 (1959)

Argued

Thursday, October 16, 1958

Decided

Monday, March 9, 1959

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for United States, 4 vote(s) against
Legal provision: Motor Carrier

None

Green v. United States

Mon, 05 Jan 2009 16:29:55 +0000

Case Basics

Docket No.

100

Petitioner

Green

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Warren Court (1957-1958)

Decided By

Warren Court (1957-1958)

Opinion

356 U.S. 165 (1958)

Argued

Monday, October 21, 1957

Decided

Monday, March 31, 1958

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for United States, 4 vote(s) against
Legal provision: 18 U.S.C. 401

None

Nilva v. United States

Mon, 05 Jan 2009 16:25:47 +0000

Case Basics

Docket No.

Petitioner

Nilva

Respondent

United States

Heard By

Warren Court (1956-1957)

Decided By

Warren Court (1956-1957)

Opinion

352 U.S. 385 (1957)

Argued

Thursday, November 8, 1956, Tuesday, November 13, 1956

Decided

Monday, February 25, 1957

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for United States, 4 vote(s) against
Legal provision:

None

Yates v. United States

Mon, 20 Jun 2011 04:05:57 +0000

Location

US District Court for the Central District of California

312 N Spring St Los Angeles CA 90012

Los Angeles, CA 90012

United States

34° 3' 25.92" N, 118° 14' 35.16" W

See map: Google Maps

Case Basics

Docket No.

Petitioner

Oleta O'Connor Yates

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Warren Court (1956-1957)

Decided By

Warren Court (1957-1958)

Opinion

355 U.S. 66 (1957)

Argued

October 9-10, 1956

Reargued:

Tuesday, October 22, 1957

Decided

Monday, November 25, 1957

Advocates

Leo Branton Jr. (argued the cause for the petitioner)

Kevin T. Maroney (for the United States on the original argument)

Philip R. Monahan (for the United States on reargument)

Facts of the Case

On June 30, 1952, during testimony in the case of United States v. Schneiderman, Oleta O'Connor Yates, an admitted leader of the Communist Party of California, refused to answer eleven questions regarding the identities of other members of the party. For her refusal Yates was found in criminal contempt and sentenced to eleven concurrent sentences of one year. The judge in the case stated that if Yates answered the questions within sixty days of conviction, he would accept her testimony. Yates continued to refuse. Yates appealed the contempt convictions on the ground that the court's intention was to coerce her to testify, rather than punish her. This would make the contempt charges civil, rather than criminal, and Yates' convictions would be a violation of due process. Yates further claimed that eleven contempt sentences for a line of questioning also violated due process. The U.S. Ninth Circuit Court of Appeals rejected Yates' claims and upheld her convictions.

Question

Did Yates' contempt convictions violate the Due Process Clause of the Fifth Amendment?

Conclusion

Decision: 6 votes for Yates, 3 vote(s) against
Legal provision:

In a 6-3 decision authored by Justice Tom C. Clark, the Court found that Yates' contempt convictions were indeed criminal, but also found that eleven convictions for what amounted to a single instance of contempt violated due process. The judge in the case stated that, were Yates to concede to answer the questions, she would still be held for contempt, even though the court would accept her testimony. This, the Court reasoned, indicated that the convictions were intended to punish Yates and not to coerce her testimony. However, the Court also found that every question for which Yates was found in contempt "fell within the same area of refusal." Noting that it would be improper for the prosecution to multiply contempts by repeated questioning on the same inquiry, the Court vacated all but the first conviction for contempt.

Cammer v. United States

Mon, 05 Jan 2009 16:25:33 +0000

Case Basics

Docket No.

110

Petitioner

Cammer

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Warren Court (1955-1956)

Decided By

Warren Court (1955-1956)

Opinion

350 U.S. 399 (1956)

Argued

Tuesday, January 24, 1956

Decided

Monday, March 12, 1956

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Cammer, 0 vote(s) against
Legal provision: 18 U.S.C. 401

None

Pounders v. Watson

Mon, 05 Jan 2009 16:15:43 +0000

Case Basics

Docket No.

96-1383

Petitioner

Pounders

Petitioner Type

Petitioner

Respondent

Watson

Respondent Type

Respondent

Decided By

Rehnquist Court (1994-2005)

Opinion

521 U.S. 982 (1997)

Decided

Friday, June 27, 1997

Facts of the Case

A California trial judge convicted attorney Penelope Watson of summary contempt for her conduct in court. After the judge had stated repeatedly not to discuss punishment, Watson asked her client whether he was facing the death penalty and whether he was facing life without possibility of parole. The judge found that Watson had willfully refused to comply with his order not to discuss punishment and that Watson's questions had permanently prejudiced the jury in favor of her client. On appeal, Watson argued that her due process rights were violated because she did not have notice of the prohibited conduct and because the trial judge could not have known without a hearing whether her conduct was willful. Ultimately, the Court of Appeals, in reversing, concluded that Watson had not engaged in a pattern of repeated violations that had pervaded the courtroom and threatened the dignity of the court.

Question

Did the Court of Appeals misinterpret the Constitution's due process requirements as applied to an attorney's summary contempt conviction for willful defiance when questioning her client?

Conclusion

Decision: 7 votes for Pounders, 2 vote(s) against
Legal provision: Due Process

Yes. In a per curiam opinion, the Court held that the Court of Appeals had misinterpreted the Constitution's due process requirements for the imposition of a summary contempt order. The Court reasoned that the trial judge's findings concerning jury prejudice, together with the judge's assessment of the flagrance of Watson's defiance, supported the finding of the need for summary contempt to vindicate the court's authority. Justice John Paul Stevens, joined by Justice Stephen G. Breyer, dissented. Justice Stevens argued that it was not so clear whether the circumstances justified a summary contempt proceeding by the judge before whom the contempt had occurred as to justify the Court's summary reversal.