U.S. Supreme Court
In re Little, 404 U.S. 553 (1972)
In re Little
Decided January 24, 1972
404 U.S. 553
Petitioner defended himself at his criminal trial when his motion for continuance, by reason of another trial engagement of his retained counsel, was denied. The court adjudged petitioner in contempt for stating in summation after the close of evidence that the court was biased and had prejudged his case, and that petitioner was a political prisoner.
Held: Petitioner's statements did not constitute criminal contempt, as they were not uttered in a boisterous tone, did not actually disrupt the court proceeding, or constitute an imminent threat to the administration of justice. Holt v. Virginia, 381 U. S. 131.
Certiorari granted; reversed.