Jon Comstock v. State of Arkansas

Summary

The court held that the district judge was acting as a circuit judge under Administrative Order No. 18 when he summarily found Comstock in direct criminal contempt, making the contempt order a final circuit-court judgment reviewable on appeal rather than by a de novo circuit-court trial. The court further held that substantial evidence supported the contempt finding based on Comstock's disruption of the proceedings, interruptions, refusal to leave, and challenge to the judge to hold him in contempt. The court declined to reach the recusal issue because it affirmed the contempt finding.