Speer v. State (1999)

But see J.D.J. v. State, 120 So.3d 229 , 230 n. 1 (Fla. 4th DCA 2013) (opining that, absent an adequate excuse for nonappearance, a defendant's failure to appear may be summarily punished as direct criminal contempt and recognizing that in Kelley the Second District disagreed with the Fourth District’s position on this point); Speer v. State, 742 So.2d 373, 373 (Fla. 1st DCA 1999) (opining that the failure to appear in court pursuant to a court order can constitute direct cr…

Compare Speer, 742 So.2d at 373 (treating the failure to appear as direct criminal contempt, but holding there was insufficient evidence to support the contempt order), with Villate v. State, 663 So.2d 672, 673 (Fla. 4th DCA 1995) (affirming finding of indirect criminal contempt for failing to appear as a witness).

See Speer v. State, 742 So.2d 373, 373 (Fla. 1st DCA 1999) (holding that the “failure to appear in court pursuant to a court order can constitute direct criminal contempt.”).

See Speer, 742 So.2d at 373 (reversing direct criminal contempt order for failure to appear where nothing in record indicated appellant had been ordered to appear); see also Bouie v. State, 784 So.2d 521 (Fla. 4th DCA 2001) (same).

See Speer v. State, 742 So.2d 373 (Fla. 1st DCA 1999); Woods v. State, 600 So.2d 27 (Fla. 4th DCA 1992). [4] It is important to note that the actual holding of Aron is much more limited than suggested by Speer and Woods .

See Speer v. State, 742 So.2d 373 (Fla. 1st DCA 1999) (A judgment of contempt for failure to appear requires reversal where the record does not indicate that the defendant was ordered to appear in court.).