In re Chambers, 142 N.E.3d 1243

During a criminal proceeding involving her son, Chambers violated a courthouse cellphone ban; her phone was confiscated and she later returned and allegedly acted belligerently toward courtroom staff while the judge was in chambers.
The judge, informed by the bailiff and a deputy (neither sworn), held a "direct contempt" hearing the next morning without written charges or counsel and sentenced Chambers to three days in jail (M-180625).
While being escorted out, the judge allegedly observed additional screaming in the hallway, brought Chambers back, found her in contempt again, and imposed a consecutive ten-day jail term (M-180624).
Chambers requested an attorney at the first hearing but was denied; counsel was appointed while she was serving the sentences, and counsel later unsuccessfully moved to mitigate the sentence. Chambers appealed both contempt findings after serving her sentences.
The court analyzed mootness separately for the two contempt findings and whether summary contempt procedures were permissible when the judge lacked personal knowledge of all alleged misconduct.
Holding: the appeal concerning the hallway contempt (M-180624) was dismissed as moot; the contempt finding in M-180625 was reversed and remanded because the court failed to follow R.C. 2705.03 when the judge lacked personal knowledge of the alleged contempt.

Issue	State's Argument	Chambers' Argument	Held
Mootness: Did Chambers voluntarily complete her sentences so the appeals are moot?	Chambers voluntarily served the sentences and failed to seek a stay; appeals are moot.	Service was not voluntary: she requested counsel, was denied at first, later obtained counsel and sought mitigation and appeal.	M-180624: appeal dismissed as moot. M-180625: not moot as to contempt finding because she served part of sentence before counsel, so appeal preserved.
Use of summary direct-contempt procedure when judge did not personally witness alleged acts	Judge may summarily punish direct contempt; his reliance on courtroom staff was sufficient.	Summary procedure unconstitutional where judge lacked personal knowledge; R.C. 2705.03 procedures (written charge, hearing, counsel) required.	Reversed M-180625: judge lacked personal knowledge of significant alleged acts and relied on others; R.C. 2705.03 procedures must be followed—summary contempt was improper.
Sufficiency/Beyond-a-reasonable-doubt proof of contempt	Conduct (belligerence, refusal to surrender phone, screaming) met criminal-contempt standard.	Record does not prove contempt beyond reasonable doubt.	Not addressed on merits (second assignment rendered moot after reversal); court reversed on procedural due-process ground instead.

Cleveland Hts. v. Lewis, 129 Ohio St.3d 389 (Ohio 2011) (tests whether completion of sentence was "voluntary" for mootness of appeal)
State v. Wilson, 41 Ohio St.2d 236 (Ohio 1975) (general rule: voluntary completion of sentence renders appeal moot absent collateral consequences)
State ex rel. Seventh Urban, Inc. v. McFaul, 5 Ohio St.3d 120 (Ohio 1983) (when judge lacks personal knowledge of alleged contempt, R.C. 2705.03 procedures must be followed)
In re Oliver, 333 U.S. 257 (U.S. 1948) (summary contempt requires judge's personal knowledge; otherwise due process demands a full hearing)
Denovchek v. Bd. of Trumbull Cty. Commrs., 36 Ohio St.3d 14 (Ohio 1988) (definition and purposes of contempt powers)
Brown v. Executive 200, Inc., 64 Ohio St.2d 250 (Ohio 1980) (criminal contempt triggers criminal-due-process protections)