State v. Puleo, 2022 Ohio 4040

Defendant Alberta J. Puleo was charged with disorderly conduct for repeatedly threatening a neighbor; she pleaded not guilty and proceeded to a bench trial.
During the bench trial Puleo repeatedly spoke out of turn and made audible comments after multiple court admonitions to stop.
The trial court found Puleo guilty of disorderly conduct and also summarily found her in direct contempt for willfully disregarding the court’s orders and disrupting proceedings.
The court deferred sentencing pending reports, later imposed fines, suspended confinement, 18 months probation with conditions (including a no-contact order), and a suspended 30-day confinement for contempt.
On appeal Puleo argued the contempt conviction was unsupported because her conduct did not show willful defiance or an imminent threat to the administration of justice.
The appellate court affirmed, giving deference to the trial court’s discretion and distinguishing cases where a single non-disruptive remark was held insufficient for contempt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the finding of direct contempt was supported by the record	Repeated interruptions after explicit warnings constituted misbehavior in the court’s presence that impeded its functions	Puleo: single or non-disruptive comments do not amount to direct contempt absent an imminent threat to administration of justice (citing Conliff and Brannon)	Affirmed: trial court did not abuse discretion; repeated interruptions after warnings supported contempt finding

Denovchek v. Bd. of Trumbull Cty. Commrs., 36 Ohio St.3d 14, 520 N.E.2d 1362 (1988) (defines contempt and explains deference to trial-court contempt determinations)
State v. Conliff, 61 Ohio App.2d 185, 401 N.E.2d 469 (10th Dist. 1978) (held an isolated, non-disruptive remark after proceedings concluded did not constitute punishable direct contempt)