State v. Puleo

Summary

The Ohio Court of Appeals, Eleventh Appellate District, affirmed Alberta J. Puleo’s convictions and sentences for disorderly conduct and direct criminal contempt. The court held that the trial court did not abuse its discretion in finding contempt based on Puleo’s repeated interruptions and continued disregard of warnings during the proceedings.

Holdings

1. A defendant's repeated interruptions of court proceedings, continued after the trial court's warnings to stop, may constitute direct criminal contempt because the conduct obstructs or impedes the administration of justice and disregards judicial orders.
2. The trial court did not abuse its discretion in finding Puleo guilty of direct criminal contempt.

Questions Presented

1. Whether Puleo's repeated interruptions and continued disregard of the trial court's warnings constituted direct criminal contempt under R.C. 2705.01.
2. Whether the trial court abused its discretion by finding Puleo guilty of direct contempt when her conduct allegedly did not constitute an imminent threat to the administration of justice.

Disposition

affirmed