State v. Smith

Citations

• 2025 Ohio 581

Syllabus

Trial court abused its discretion by summarily holding individual in direct criminal contempt for allegedly contemptuous conduct that occurred outside the trial court's physical presence and of which the court had no personal knowledge. Under those circumstances, the trial court was required to comply with the procedural requirements of R.C. 2705.03. Although the trial court conducted a contempt hearing, no written charge was filed with the clerk of court and no entry of the charge was made on the journal; therefore, the procedural requirements were not satisfied.