State of Minnesota v. Blair Benedict Oberton

Syllabus

1. This appeal is not moot because the collateral consequences exception to the mootness doctrine applies. 2. Although 180 days is the maximum sentence allowed by law when direct contempt is summarily sentenced for punitive purposes under a district court's inherent authority, a district court should, as a matter of comity to the Legislature, limit its sentence—consistent with the maximum sentence for statutory misdemeanor contempt— to 90 days and a $1,000 fine unless the person's conduct is extraordinary. 3. In the exercise of our supervisory power to ensure the fair administration of justice, we announce that when a district court determines in a contempt order that a defendant's conduct is extraordinary, the court must make oral or written findings describing the extraordinary conduct within 7 days of the direct contempt order so that an appellate court is able to review the district court's order for arbitrariness, capriciousness, and oppressiveness. Reversed and remanded.