Commonwealth v. Stevenson’s Empirical Analysis
1978
Citation profile
40 state decisions
How this case has been cited
Cited by 40 later decisions — most recently August 2023 · most notably Commonwealth v. Marcone (1980), In re Dodson (1990)
40 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
Applies 18 U.S.C. § 401
Relies on Ungar v. Sarafite · Offutt v. United States · Cooke v. United States · Thompson v. City of Louisville · Mayberry v. Pennsylvania
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 40 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We think the distinction [between contempt merely “in the presence of the court” and that which takes place “in open court” or “in the face of the court,” thereby justifying the departure from the traditional view of due process requirements,] finds its reason not any more in the ability of the judge to see and hear what happens in the open court than in the danger that, unless such an open threat to the orderly procedure of the court and such a flagrant defiance of the person and presence of the judge before the public in the very hallowed place of justice ... is not instantly suppressed and punished, demoralization of the court’s authority will follow. Punishment without issue or trial was so contrary to the usual and ordinarily indispensable hearing before judgment constituting due process that the assumption that the court saw everything that went on in open court was required to justify the exception; but the need for immediate penal vindication of the dignity of the court created it.”
2 later decisions quote this exact passage“From the same necessity that in a proper case warrants summary punishment for contempt comes also the permissibility of the imposition of sanctions by the judge who heard and saw the misconduct. But when that necessity is absent, the reason for allowing the judge who has been the object of insult to preside over the hearing is also absent. As a constitutional matter, recusal is required when the record reveals a “running, bitter controversy” between the judge and the offender. Mayberry v. Pennsylvania, 400 U.S. 455, 465 , 91 S.Ct. 499, 505 , 27 L.Ed.2d 532, 540 (1971). Commonwealth v. Stevenson, supra 482 Pa. at 91 , 393 A.2d at 394 .”
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: (1) The official misconduct of the officers of such courts respectively. (2) Disobedience or neglect by officers, parties, jurors or witnesses of or to the lawful process of the court. (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.