In re Stewart
United States Court of Appeals for the Fifth Circuit
571 F.2d 958 (1978)
Murray Stewart (defendant), supervisor of county laborer Thomas Stubblefield, transferred Stubblefield to a different crew after Stubblefield was called for federal jury duty, though Stewart told Stubblefield the transfer wasn't related to jury service and his pay would remain the same; when Stubblefield reported this to Judge Cox (who had presided over the jury trial), Stewart was arrested and held without bail, tried without ever being informed of or waiving his right to counsel, and the U.S. attorney was directed to prosecute. At trial, Judge Cox stated he wished to "make an example" of Stewart and imposed a $100 fine and probation; Stewart appealed.
Whether criminal-contempt proceedings in federal court must comport with ordinary criminal due-process requirements, including notice, the right to counsel, and geographic proximity to the court for out-of-court conduct.