United States v. Robert Peoples, 698 F.3d 185

Peoples, a former inmate, filed multiple § 1983 civil actions against prison officials in federal court in South Carolina.
The district court scheduled three cases for jury selection in February 2011 before Judge Currie.
Peoples arrived late on several occasions; Judge Currie warned of dismissal with prejudice if late again.
On March 23, 2011, after a delay due to a tire problem, a second trial proceeded; Peoples was disruptive and warned of possible contempt.
On April 12, 2011, after a third trial day, Judge Currie dismissed the case with prejudice for willful lateness, and Peoples muttered as jurors were brought in.
A subsequent contempt inquiry led to two trials before Judge Conrad: first for the courtroom outburst and second for tardiness; the first found guilty and imprisoned Peoples for four months, the second found him guilty and sentenced him to 30 days.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the first contempt conviction was supported by evidence of misbehavior	Peoples argues no misbehavior occurred.	Conrad held the outburst directed at the court constituted misbehavior.	Affirmed
Whether the outburst obstructed the administration of justice	Outburst did not impede judicial duties.	Outburst caused delay and distraction in court proceedings.	Affirmed the obstruction finding
Whether the second contempt conviction was procedurally valid under Rule 42	Second contempt proceeded improperly without Rule 42(a) safeguards.	Court purported to follow Rule 42(b) but did not provide full safeguards.	Reversed; due process violation required reversal

United States v. Warlick, 742 F.2d 113 (4th Cir. 1984) (defines obstruction of justice in context of contempt)
In re McConnell, 370 U.S. 230 (1962) (obstruction requires disruption of judicial duty)
In re Sealed Case, 627 F.3d 1235 (D.C. Cir. 2010) (conduct after proceedings may still obstruct justice)
Gordon v. United States, 592 F.2d 1215 (1st Cir. 1979) (utterance of insults can be contemptuous in presence of court)
In re Gates, 600 F.3d 333 (4th Cir. 2010) (procedural safeguards required for summary contempt)
In re Contempt Order, 441 F.3d 1266 (10th Cir. 2006) (absence of appearance does not automatically justify contempt)
In re Chandler, 906 F.2d 248 (6th Cir. 1990) (tardiness of counsel not contempt in the presence of the court)
United States v. Nunez, 801 F.2d 1260 (11th Cir. 1986) (counsel tardiness generally not contempt in presence)
United States v. Oberhellmann, 946 F.2d 50 (7th Cir. 1991) (analysis of contempt in proximity to court actions)
United States v. Bagwell, 512 U.S. 821 (1994) (due process rights in criminal contempt)
United States v. Olano, 507 U.S. 725 (1993) (harmless-error and substantial rights framework)
Mathews v. Eldridge, 424 U.S. 319 (1976) (due process requires meaningful opportunity to be heard)