People of Michigan v. Kevin Michael-Ferdina Richards, 333122

Defendant Kevin Michael-Ferdina Richards was found in criminal contempt and sentenced to 30 days in jail, to run concurrently with his aggravated domestic violence sentence.
The contempt finding was based on defendant’s tardiness to a November 16, 2015 bond hearing (arriving ~10 minutes late) and cumulative disruptive behavior throughout the case.
Earlier incidents: defendant was late and talking on a cellphone at an October 26, 2015 motion hearing; he repeatedly interrupted and was argumentative at his November 3, 2015 plea hearing.
At the November 16 hearing defendant interrupted testimony, made disruptive gestures while the court was ruling, and offered implausible excuses for tardiness that the trial court found not credible.
The trial court had warned defense counsel that defendant would be held in contempt if late; the court viewed the contempt as criminal (punishment for completed acts) and imposed jail time after finding willful, disorderly, and disrespectful conduct.
On appeal defendant argued there was no willful disobedience and that a single tardiness instance did not harm court proceedings; the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supported criminal contempt for tardiness and courtroom misconduct	Court (prosecution) argued defendant’s late arrival plus pattern of disruptive behavior justified contempt to vindicate court authority	Richards argued he did not willfully disobey or meaningfully disrupt proceedings; tardiness alone insufficient	Affirmed: competent evidence proved willful, disorderly, contemptuous conduct; contempt sanction proper
Whether contempt was criminal or civil and required proof beyond a reasonable doubt	Court treated contempt as criminal because it punished completed acts beyond court’s immediate view	Richards implied lesser standard or argued procedural infirmity	Held criminal contempt; proof beyond a reasonable doubt satisfied
Whether the trial court abused discretion in sanction severity (30 days)	Court maintained jail time appropriate to restore order and respect for process	Richards contended brief tardiness did not merit jail when viewed in isolation	Held within range of principled outcomes given cumulative misconduct; no abuse of discretion
Whether court’s credibility findings were reviewable on appeal	Prosecution relied on trial court’s firsthand observations and reputation for patience	Richards challenged credibility findings and claimed lack of negative effect on court	Held appellate court defers to trial court credibility assessments; no clear error

In re Contempt of Henry, 282 Mich. App. 656 (standard of review for contempt findings) (discussing deference to trial court credibility and clear-error review)
In re Contempt of Dudzinski, 257 Mich. App. 96 (contempt defined as willful acts that impair court authority)
In re Contempt of Robertson, 209 Mich. App. 433 (courts have inherent and statutory contempt authority)
Kirby v. Michigan High School Athletic Ass’n, 459 Mich. 23 (parties must obey court orders despite possible error or face contempt)
In re Contempt of Rochlin, 186 Mich. App. 639 (distinction between criminal and civil contempt)
Porter v. Porter, 285 Mich. App. 450 (criminal contempt requires proof beyond a reasonable doubt and certain procedural protections)
People v. Kammeraad, 307 Mich. App. 98 (trial court did not abuse discretion holding defendant in contempt based on cumulative misconduct)