In Re Contempt of Kathy H Murphy

Summary

The Michigan Supreme Court held that a nonsummary contempt proceeding could not be ordered after Murphy's summary criminal-contempt conviction was vacated because the trial court had failed to make findings and create a reviewable record. Although summary proceedings were initially authorized because the alleged conduct occurred in the judge's presence, remand would be futile after the underlying proceeding had ended, Murphy had served her sentence, and the contempt's courtroom-order purpose had been fulfilled. The Court declined to decide whether double jeopardy independently barred the remand.