In Re Joseph A. Hurley

Summary

The Court held that both $1,000 contempt sanctions imposed on Hurley were criminal rather than civil because they punished past violations without providing an opportunity to purge the fines. Because the conduct involved tardiness and statements made outside the court's presence, the Superior Court could not adjudicate the charges summarily and was required to provide advance notice and a separate hearing. The contempt orders were reversed and remanded for possible orders to show cause and hearings.