In Re Reece, 341 S.W.3d 360

Relator Coy Reece was held in contempt for perjuring himself during a 2008 deposition in a civil SB International, Inc. suit and was confined for 60 days with most of the sentence suspended.
SB sought sanctions for discovery abuses; a hearing on sanctions occurred, but a show-cause order on contempt preceded a full contempt hearing.
Reece admitted to deliberate misstatements under oath during the deposition, admitting lying to impede SB's discovery efforts.
The underlying action is civil; after confinement, Reece sought habeas relief from the Court of Criminal Appeals, which declined to exercise habeas jurisdiction and directed him to seek relief in this Court.
This Court concluded the trial court abused its discretion by holding Reece in contempt for deposition perjury, because perjury alone did not obstruct the court, and because the Court of Criminal Appeals declined habeas review, mandamus was appropriate to vacate the contempt judgments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is deposition perjury punishable as contempt	Reece argues perjury in a deposition cannot support contempt.	SB contends construction of contempt can cover deposition perjury if it obstructs the court.	Perjury in deposition alone does not constitute contempt unless it obstructs court duties.
Did the trial court abuse discretion in contempt	Reece asserts no obstruction to court, thus no contempt.	SB maintains contempt was proper to punish deceptive deposition testimony.	Trial court abused its discretion; contempt judgments void for lack of obstruction.
Whether mandamus is proper where habeas is unavailable	Reece seeks mandamus to obtain relief due to lack of habeas review.	SB argues mandamus cannot bypass a statutory habeas limitation.	Mandamus is proper where there is no adequate remedy by appeal and habeas is unavailable.
Adequacy of remedy by appeal given civil underlying case	Reece has no adequate appellate remedy in light of CA declines habeas jurisdiction.	SB asserts there is some remedy via the Court of Criminal Appeals or other channels.	Relief via mandamus is appropriate because there is no adequate remedy by appeal.

Ex parte Chambers, 898 S.W.2d 257 (Tex.1995) (establishes contempt power as broad but to be used with caution)
Ex parte Hudgings, 249 U.S. 378 (S. Ct. 1919) (perjury alone does not justify contempt unless it obstructs justice)
In re Michael, 326 U.S. 224 (S. Ct. 1945) (perjury alone does not sustain contempt; obstruction required)
Ex parte Krupps, 712 S.W.2d 149 (Tex.Crim.App.1986) (constructive contempt requires obstructing court duties)
In re Long, 984 S.W.2d 623 (Tex.1999) (contempt not involving confinement reviewed by mandamus; fine-only contexts)
Rosser v. Squier, 902 S.W.2d 962 (Tex.1995) (mandamus available where habeas unavailable for contempt matters not involving confinement)