PA Man Held in Contempt After Calling Judge a Nasty Name
Posted in General on June 27, 2025
In Commonwealth v. Outlaw, the Pennsylvania Superior Court upheld a direct criminal contempt conviction after a defendant called the judge a profanity during a hearing. This case highlights how verbal outbursts and disruptive behavior in a Pennsylvania courtroom can quickly escalate into a criminal contempt charge under 42 Pa.C.S. § 4132(3).
🧑⚖️ What Happened in Commonwealth v. Outlaw?
During a suppression hearing in Philadelphia, the defendant, after receiving an unfavorable ruling, loudly called the presiding judge a “cocksucker” and attempted to leave the courtroom.
The judge immediately paused proceedings.
Outlaw was taken into custody.
A summary criminal contempt hearing followed, resulting in a 15 to 30-day sentence.
The defendant appealed, arguing that although the comment was inappropriate, it didn’t rise to the level of actual obstruction required for contempt.
📚 Legal Background: What Is Direct Criminal Contempt in Pennsylvania?
Under 42 Pa.C.S. § 4132(3), a person can be held in direct criminal contempt if they:
Commit misconduct in the presence of the court;
Intend to obstruct or disrupt proceedings;
And their behavior actually prejudices or interrupts the court’s ability to conduct business.
The offense is often handled summarily, meaning without a jury trial, especially when it occurs in real time during proceedings.
🧠 Court’s Analysis: When Does Speech Become Contempt?
The Superior Court disagreed with Outlaw. Key points in its reasoning:
The outburst was intentional, loud, and directed at the judge.
The proceeding was halted, however briefly.
The conduct undermined the dignity and authority of the court.
Even a short disruption can meet the legal standard if it poses a threat to orderly procedure or inspires future disorder.
Appeal to Pennsylvania Supreme Court
This decision is currently on appeal to the Pennsylvania Supreme Court. The issue is:
- Where this Court has declared that disrespectful or insulting remarks towards a judge without more is not contemptuous conduct, can a single act of profane name-calling directed at the judge constitute direct criminal contempt?
We will have to wait and see what the Supreme Court decides. This could have been avoided by simply not calling the judge a cocksucker or any other name.