Arkansas Department of Human Services, Erica Eneks, and Tony Huffman v. Tegan Dowdy and Minor Children

Summary

The court affirmed criminal-contempt findings against a DHS attorney and caseworker who arranged for the caseworker to leave before a child-custody hearing so that potentially relevant testimony would not be presented. Because the penalties were unconditional, the contempt was criminal, and because the conduct occurred in the judge's presence, it was direct contempt subject to summary punishment. The court held that substantial evidence and reasonable inferences supported both findings.