http://www.courts.state.pa.us/OpPosting/Superior/out/s52017_04.pdf
Defendant talked to Plaintiff (asked her about her health) during contempt hearing, in open court.
Lower court found him guilty of contempt.
Superior Court reversed. Held, no wrongful intent in talking to Plaintiff/wife in courtroom, while D shackled, P protected by deputy sheriff, P testified that she wasn’t afraid.
Issue of whether indirect criminal contempt could be found where act took place in the presence of the court was mentioned (in bold type) but never resolved.
Don Marritz, MidPenn Legal Services
