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defendantappealtrialdue process
defendantlawyertrialmotiondue process

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Mayberry v. Pennsylvania, 400 U.S. 455, 91 S.Ct. 499, 27 L.Ed.2d 532

Facts

Mayberry and two co-defendants were tried for prison breach and holding hostages, representing themselves with appointed counsel as advisors. Throughout the trial, Mayberry made numerous outbursts against the judge, including personal insults and accusations of bias. The judge found him guilty of contempt for his behavior over the course of the trial, resulting in a sentence of 11 to 22 years for the contempt charges.

Petitioner's conduct at the trial comes as a shock to those raised in the Western tradition that considers a courtroom a hallowed place of quiet dignity as far removed as possible from the emotions of the street.

Issue

Whether a defendant in a criminal contempt proceeding is entitled to a public trial before a judge other than the one who has been insulted by the defendant.

Whether a defendant in a criminal contempt proceeding is entitled to a public trial before a judge other than the one who has been insulted by the defendant.

Rule

Under the Due Process Clause of the Fourteenth Amendment, a defendant in criminal contempt proceedings should be given a public trial before a judge other than the one reviled by the contemnor.

Under the Due Process Clause of the Fourteenth Amendment, a defendant in criminal contempt proceedings should be given a public trial before a judge other than the one reviled by the contemnor.

Analysis

The Supreme Court found that the trial judge's personal involvement and the insults directed at him compromised the fairness of the contempt proceedings. The Court emphasized that a judge who has been personally attacked may not be able to maintain the necessary impartiality required for a fair trial. Therefore, the Court ruled that the contempt conviction should be vacated and retried before a different judge.

The Court noted in Sacher v. United States, 343 U.S. 1, 10, 72 S.Ct. 451, 455, 96 L.Ed. 717, that, while instant action may be taken against a lawyer who is guilty of contempt, to pronounce him guilty of contempt is ‘not unlikely to prejudice his client.’ Those considerations are not pertinent here where petitioner undertook to represent himself.

Conclusion

The U.S. Supreme Court vacated the contempt conviction and remanded the case for a new trial before a different judge, emphasizing the importance of due process in maintaining the integrity of the judicial system.

We conclude that that course should have been followed here, as marked personal feelings were present on both sides.

Who won?

Mayberry prevailed in the appeal as the Supreme Court ruled in his favor, stating that he was entitled to a fair trial before an impartial judge.

The Supreme Court held that by reason of due process clause of Fourteenth Amendment a defendant in criminal contempt proceedings should be given public trial before judge other than one reviled by contemnor.

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