Roberts v. Farrell

Citations

• 212 N.E.3d 432
• 2023 Ohio 1109

Syllabus

CIVIL CONTEMPT CRIMINAL CONTEMPT INDIRECT CONTEMPT DIRECT CONTEMPT INTENT TO DEFY PUNITIVE. Intent to defy the court is an essential element of indirect criminal contempt that must be established beyond a reasonable doubt. Failure to appear at a hearing is indirect contempt. When determining whether a contempt is criminal or civil in nature, courts look to the purpose of the proceeding. Criminal contempt seeks to punish an affront to the dignity of the court or the legal process. Thus, criminal contempt has a punitive purpose rather than a coercive or remedial purpose.