In re McDonald, 98 So. 3d 1040

Chancellor Harris found Jernigan, McDonald, and Cheshire in civil contempt for filing false proof-of-service affidavits in DHS paternity/child-support cases.
At a separate sentencing hearing, the court imposed joint and several sanctions totaling $88,500, plus apologies and a ban on serving/notarizing in the district, with weekend incarceration until paid.
The court later treated the judgments as constructive criminal contempt rather than civil contempt.
Defendants appealed and sought habeas relief; the Supreme Court clarified the proceedings were constructive criminal contempt and due-process safeguards applied.
The Mississippi Supreme Court vacated the contempt judgments for procedural due-process violations and remanded for recusal and proper notice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural due process for constructive criminal contempt	Jernigan, McDonald, and Cheshire claim proper process was lacking.	Chancellor Harris improperly initiated and conducted the proceedings without recusal and without proper notice.	Procedural due process violations require vacatur and remand.
Mootness of merits given procedural defects	Merits should be reached if procedurally proper.	If due-process errors exist, merits need not be addressed.	Merits deemed moot; due-process defects mandate vacatur and remand.

Graves v. State, 66 So.3d 148 (Miss. 2011) (indirect constructive contempt requires due-process safeguards)
Purvis v. Purvis, 657 So.2d 794 (Miss. 1994) (constructive contempt requires notice and a hearing)
In re Williamson, 838 So.2d 226 (Miss. 2002) (recusal when judge initiates constructive contempt)
In re Smith, 926 So.2d 878 (Miss. 2006) (recusal principle for constructive contempt proceedings)
Cooper Tire & Rubber Co. v. McGill, 890 So.2d 859 (Miss. 2004) (due-process expectations in contempt context)
Shavers v. Shavers, 982 So.2d 397 (Miss. 2008) (contempt proceedings require proper notice)