State of Minnesota, Respondent, vs. Royden Helsing, Appellant, a260039

Helsing sued Carlson in conciliation court, and at a December 10, 2025 district court hearing he repeatedly interrupted proceedings, laughed at Carlson, used profane and derogatory language toward the judge, and was found in direct contempt. 1
The district court summarily sentenced Helsing to ten days in jail and ordered him to report immediately to serve the sentence. 2
Helsing sought reconsideration, then filed a petition for a writ of prohibition, which this court construed as an appeal from a final misdemeanor judgment. 3
Helsing argued on appeal that the contempt should have been reviewable by prohibition, that the court lacked a basis for direct contempt, that due process required warning or allocution, and that ten days was excessive. 4
The state responded that Helsing's conduct was direct contempt committed in the court's presence and that the ten-day sanction was reasonable compared with similar cases. 5

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the writ petition could be reconsidered as prohibition 6	Helsing sought prohibition review of summary imprisonment	State said this court already construed it as an appeal	No reconsideration; appeal construction stands 7
Whether Helsing's conduct was direct contempt 8	Helsing said mental condition made it constructive contempt	State said repeated in-court disruptions were direct contempt	Conduct was direct contempt 9
Whether due process required prior warning or allocution 10	Helsing claimed warning and allocution were required	State said statute and cases require neither	No due process violation 11
Whether the ten-day jail sanction was an abuse of discretion 12	Helsing said lesser sanctions would suffice	State said similar conduct supported equal or greater punishment	Ten-day sanction was not an abuse of discretion 13

In re Welfare of Child. of J.B., 782 N.W.2d 535 (Minn. 2010) (contempt decisions reviewed for abuse of discretion 14)
State v. Tatum, 556 N.W.2d 541 (Minn. 1996) (distinguishes punitive and remedial contempt; abuse-of-discretion review for contempt 15)
In re Cary, 206 N.W. 402 (Minn. 1925) (appellate courts defer to the trial court's assessment of contemptuous demeanor 16)
Fletcher v. St. Paul Pioneer Press, 589 N.W.2d 96 (Minn. 1999) (clearly erroneous standard for factual findings 17)
State v. Martin, 555 N.W.2d 899 (Minn. 1996) (warnings to recalcitrant witnesses whenever practical before contempt sanctions 18)
Taylor v. Hayes, 418 U.S. 488 (U.S. 1974) (delayed contempt punishment without hearing violated due process 19)
State v. Schloegl, 915 N.W.2d 14 (Minn. App. 2018) (profane courtroom outburst supported a substantial contempt sentence 20)
State v. Oberton, 10 N.W.3d 64 (Minn. 2024) (upholding a lengthy contempt sentence for a profanity-laced attack on the court 21)
State v. Lingwall, 637 N.W.2d 311 (Minn. App. 2001) (upholding a six-month contempt sentence for a highly aggravated verbal attack 22)
Fitzgerald v. Fitzgerald, 629 N.W.2d 115 (Minn. App. 2001) (self-represented litigants generally held to the same standards as attorneys 23)
State ex rel. Leftwich v. Dist. Ct., 42 N.W. 598 (Minn. 1889) (criminal contempt orders are rarely reversed absent clear arbitrariness 24)