N.Y. Jud. Law § 755

§ 755. When punishment may be summary. Where the offense is committed\nin the immediate view and presence of the court, or of the judge or\nreferee, upon a trial or hearing, it may be punished summarily. For that\npurpose, an order must be made by the court, judge, or referee, stating\nthe facts which constitute the offense and which bring the case within\nthe provisions of this section, and plainly and specifically prescribing\nthe punishment to be inflicted therefor. Such order is reviewable by a\nproceeding under article seventy-eight of the civil practice law and\nrules.\n