PA Court Affirms Contempt Conviction for Courtroom Cellphone Use
Posted in General on June 29, 2025
A Pennsylvania Superior Court decision emphasizes the importance of respecting courtroom rules and judicial authority. In In re: Sheldon Arrington, 2019 PA Super 218, the court upheld a criminal contempt conviction against a long-time Allegheny County probation officer for violating the court’s cellphone policy and disobeying a judge’s direct order.
This case highlights the serious consequences of failing to follow courtroom rules in Pennsylvania—even for experienced legal professionals.
Facts of the Case: Cellphone Use Leads to Contempt Charges
A juvenile probation officer with nearly 20 years of experience, appeared at the Allegheny County Courthouse to testify as a witness in a juvenile court hearing. The courthouse has a strict prohibition against cellphone use in courtrooms, clearly posted on multiple signs.
Despite this rule, Arrington was seen texting on his phone while seated in the courtroom. After the judge entered and noticed his behavior, the judge instructed Arrington to put the phone away. Arrington refused, stating, “there’s nothing going on in here,” claimed he had an emergency, and continued using his phone.
The judge then ordered Arrington to leave the courtroom. Instead of waiting nearby, Arrington left the courthouse entirely. His absence prevented defense counsel from reaching him to testify, which ultimately led the judge to recuse himself from the case, and the matter was reassigned.
The trial court later issued a Rule to Show Cause, requiring Arrington to appear and explain why he should not be held in contempt of court.
Contempt Hearing and Sentencing
At the contempt hearing, Arrington apologized for his actions but offered no additional evidence. The trial court found him guilty of criminal contempt and sentenced him to 10 days in jail, later reducing the sentence to 5 to 10 days after reconsideration.
Arrington appealed, arguing:
There was insufficient evidence to prove he intended to disrupt the proceedings.
His sentence of jail time was excessive for the nature of the conduct.
Superior Court’s Ruling: Upholding the Contempt Conviction
The Pennsylvania Superior Court affirmed the contempt conviction and sentence, finding that all legal elements of contempt were satisfied:
1. Misconduct
Arrington’s use of a cellphone and refusal to comply with the judge’s order constituted misconduct, especially given the courthouse’s clear cellphone policy.
2. Conduct in the Presence of the Court
The violations occurred in the courtroom, directly in front of the judge.
3. Intent to Defy Court Authority
As an experienced probation officer familiar with courtroom procedures, Arrington knew or should have known his conduct was inappropriate. His refusal to follow the judge’s instructions demonstrated intent.
4. Obstruction of Justice
Arrington’s actions undermined the authority of the court and disrupted the judicial process by forcing a judge’s recusal and case reassignment.
The court also rejected Arrington’s argument regarding the severity of his sentence, noting that his 5-to-10-day jail sentence was well within the six-month maximum permitted for criminal contempt in Pennsylvania.
Key Takeaways for Courtroom Conduct in Pennsylvania
This case serves as a critical reminder that:
✅ Disobeying a judge’s direct order can lead to criminal contempt charges.
✅ Even minor acts of defiance, such as ignoring court rules, can have serious legal consequences, including jail time.
✅ The courts have broad authority to maintain order, and failure to comply can damage both the proceedings and an individual’s legal standing.