State of Minnesota v. Blair Benedict Oberton

Summary

The Minnesota Supreme Court held that Oberton’s appeal is not moot because collateral consequences apply, reaffirmed the Tatum rule that a 90‑day sentence (or $1,000 fine) is the presumptive maximum for punitive direct contempt unless conduct is extraordinary, and announced a new supervisory rule requiring district courts to make oral or written findings of extraordinary conduct within seven days when imposing a sentence between 90 and 180 days; the 180‑day sentence was vacated and a 90‑day sentence imposed on remand.