In Re Little

Summary

The Supreme Court granted certiorari, held that the petitioner's summation statements did not constitute criminal contempt, and reversed the conviction. The Court emphasized that contempt requires an imminent threat to the administration of justice, not merely vehemence, and noted that the lower courts may still address the issue under Mayberry. Justice Burger, concurring, agreed with the reversal but stressed the need for a full factual record on tone and demeanor.