State of Minnesota v. Miranda Lynn Jones, 2015 Minn. LEXIS 474

Miranda Lynn Jones was convicted of a controlled-substance offense; imposition of sentence was stayed and she was placed on supervised probation with terms including no alcohol and to remain law‑abiding.
Five months later Jones was cited for underage consumption of alcohol and disorderly conduct; the State moved to revoke probation and successfully did so, executing the sentence.
The State also charged Jones with misdemeanor criminal contempt under Minn. Stat. § 588.20, subd. 2(4) for "willful disobedience to the lawful process or other mandate of a court."
Jones moved to dismiss the contempt charge, arguing that violating a probation term is not a violation of a court "mandate" that supports prosecution for contempt; the district court granted dismissal.
The court of appeals affirmed, holding contempt prosecution for probation violations is generally inconsistent with the purpose of the contempt statute and the judicial function; the State appealed to the Minnesota Supreme Court.
The Minnesota Supreme Court affirmed: willful violation of a probation term, standing alone, does not constitute criminal contempt under § 588.20(2)(4).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Jones)	Held
Whether willful violation of a probation "term" is a "mandate of a court" under Minn. Stat. § 588.20(2)(4), permitting prosecution for misdemeanor criminal contempt	A probation term is part of the sentencing order (a court order), so willful violation is willful disobedience of a court mandate and therefore punishable as criminal contempt	A probation term is an agreed or prescribed "term," not an independent court mandate; violations are addressed by probation statutes (revocation, sanctions), not by contempt prosecution	The Court held that a willful violation of a probation term, by itself, is not a violation of a court "mandate" under § 588.20(2)(4); contempt prosecution for such violations is not authorized

Barrow v. State, 862 N.W.2d 686 (Minn. 2015) (statutory interpretation is reviewed de novo)
State v. Tatum, 556 N.W.2d 541 (Minn. 1996) (distinguishes judicial contempt and prosecutable misdemeanor contempt; contempt vindicates court authority)
State v. Austin, 295 N.W.2d 246 (Minn. 1980) (probation revocation standards and revocation as a remedy of last resort)
State v. McCormick, 273 N.W.2d 624 (Minn. 1978) (recognizing contempt liability for violation of a court order in context of child custody)