2000 Pa. Super. 165 - Commonwealth v. Williams’s Empirical Analysis
2000
Citation profile
2 federal appellate · 14 state decisions
How this case has been cited
Cited by 16 later decisions — most recently April 2024
2 federal appellate · 14 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Codispoti v. Pennsylvania · Kremer v. Grant · Krupinski v. Vocational Technical School Eastern Northampton County · Millili v. Commonwealth, Department of Transportation, Bureau of Driver Licensing · Commonwealth v. Lord
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Our Supreme Court has emphatically recognized that these [constitutional] provisions prohibit multiple punishments for the same offense at trial. An individual may be punished only once for a single act which causes a single injury to the Commonwealth. Our Supreme Court has also acknowledged that impermissible multiple punishments for a single offense can take the form of consecutive sentences. Therefore, in [Williams’] case ..., in order for the Trial Court to have imposed multiple consecutive sentences, [Williams’] conduct must have constituted two separate offenses i.e. two separate contemptuous acts. Clearly [Williams’] conduct, though of a contemptuous nature, did not constitute multiple offenses allowing the imposition of separate punishments. [Williams’] verbal utterance and hand gesture were contemporaneously executed, and [Appellant’s] hand gesture is universally recognized throughout Western civilization as having the same meaning as his foul utterance. As such, the statement and simultaneous gesture were so inextricably intertwined that they must be considered to have been one unified act of contemptuous misconduct directed toward the Trial Court. Consequently, the unified act constituted but a single violation of 42 Pa.C.S.A. § 4132(3)[, i.e., the criminal contempt statute]. The three consecutive sentences which the trial court imposed for this one contemptuous act were therefore violative of the principles of double jeopardy and they must be vacated. As a result ”
2 later decisions quote this exact passage“(1) misconduct, (2) in the presence of the court, (3) committed with the intent to obstruct the proceedings, (4) which obstructs the administration of justice. [Cjontempt requires actual, imminent prejudice to a fair proceeding or prejudice to the preservation of the court’s orderly procedure and authority. Remarks that are injudicious, or even disrespectful, will not, without more, justify a summary conviction for contempt of court.”
1 later decision quote this exact passage“The power of the several courts of this Commonwealth to issue attachments and to impose summary punishments for contempts of court shall be restricted to the following cases:, * # # (3) The misbehavior of any person in the presence of the court, thereby obstructing the administration of justice.”
1 later decision quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.