contempt hearing in District of Columbia

2001See Carver, 954 F.2d at 1578 (noting that “[w]hen requested, such relief should be liberally granted in situations involving alimony, maintenance, or support”); accord, Newman, 196 B.R. at 703 .

2001See Carver, 954 F.2d at 1578 (noting that “[w]hen requested, such relief should be liberally granted in situations involving alimony, maintenance, or support”); accord, Newman, 196 B.R. at 703 .

2000The law is clear that if a witness has declared unequivocally that he will not testify on the basis of the Fifth Amendment privilege against self-incrimination, the witness should not be placed on the stand and required to make that claim in front of the jury. “[T]he trial court may bar a witness [who invokes the Fifth Amendment privilege] from testifying in the jury’s presence if it properly concludes that the witness may refuse to answer essentially all of the questions which he *905 may be asked.” Reese v. United States, 467 A.2d 152, 157 (D.C.1983); Alston v. United States, 388 A.2d 307 ,

1996I submit that the proposition that there is an entitlement to counsel prior to adjudication resulting in incarceration is even less controversial in the case of criminal contempt — even summary contempt — proceedings than in civil contempt because, in addition to incarceration, criminal contempt results in a conviction and cannot be purged by the contemnor. [9] See, e.g., Walker v. McLain, 768 F.2d 1181, 1183 (10th Cir.1985), cert. denied, 474 U.S. 1061 , 106 S.Ct. 805 , 88 L.Ed.2d 781 (1986); Ridgway v. Baker, supra, 720 F.2d at 1413 ; United States v. Johnson, 659 F.2d 415, 416-17 (4th Cir.1

1996I submit that the proposition that there is an entitlement to counsel prior to adjudication resulting in incarceration is even less controversial in the case of criminal contempt — even summary contempt — proceedings than in civil contempt because, in addition to incarceration, criminal contempt results in a conviction and cannot be purged by the contemnor. [9] See, e.g., Walker v. McLain, 768 F.2d 1181, 1183 (10th Cir.1985), cert. denied, 474 U.S. 1061 , 106 S.Ct. 805 , 88 L.Ed.2d 781 (1986); Ridgway v. Baker, supra, 720 F.2d at 1413 ; United States v. Johnson, 659 F.2d 415, 416-17 (4th Cir.1

1996I submit that the proposition that there is an entitlement to counsel prior to adjudication resulting in incarceration is even less controversial in the case of criminal contempt — even summary contempt — proceedings than in civil contempt because, in addition to incarceration, criminal contempt results in a conviction and cannot be purged by the contemnor. [9] See, e.g., Walker v. McLain, 768 F.2d 1181, 1183 (10th Cir.1985), cert. denied, 474 U.S. 1061 , 106 S.Ct. 805 , 88 L.Ed.2d 781 (1986); Ridgway v. Baker, supra, 720 F.2d at 1413 ; United States v. Johnson, 659 F.2d 415, 416-17 (4th Cir.1

1996I submit that the proposition that there is an entitlement to counsel prior to adjudication resulting in incarceration is even less controversial in the case of criminal contempt — even summary contempt — proceedings than in civil contempt because, in addition to incarceration, criminal contempt results in a conviction and cannot be purged by the contemnor. [9] See, e.g., Walker v. McLain, 768 F.2d 1181, 1183 (10th Cir.1985), cert. denied, 474 U.S. 1061 , 106 S.Ct. 805 , 88 L.Ed.2d 781 (1986); Ridgway v. Baker, supra, 720 F.2d at 1413 ; United States v. Johnson, 659 F.2d 415, 416-17 (4th Cir.1

1996I submit that the proposition that there is an entitlement to counsel prior to adjudication resulting in incarceration is even less controversial in the case of criminal contempt — even summary contempt — proceedings than in civil contempt because, in addition to incarceration, criminal contempt results in a conviction and cannot be purged by the contemnor. [9] See, e.g., Walker v. McLain, 768 F.2d 1181, 1183 (10th Cir.1985), cert. denied, 474 U.S. 1061 , 106 S.Ct. 805 , 88 L.Ed.2d 781 (1986); Ridgway v. Baker, supra, 720 F.2d at 1413 ; United States v. Johnson, 659 F.2d 415, 416-17 (4th Cir.1

1996I submit that the proposition that there is an entitlement to counsel prior to adjudication resulting in incarceration is even less controversial in the case of criminal contempt — even summary contempt — proceedings than in civil contempt because, in addition to incarceration, criminal contempt results in a conviction and cannot be purged by the contemnor. [9] See, e.g., Walker v. McLain, 768 F.2d 1181, 1183 (10th Cir.1985), cert. denied, 474 U.S. 1061 , 106 S.Ct. 805 , 88 L.Ed.2d 781 (1986); Ridgway v. Baker, supra, 720 F.2d at 1413 ; United States v. Johnson, 659 F.2d 415, 416-17 (4th Cir.1

1996I submit that the proposition that there is an entitlement to counsel prior to adjudication resulting in incarceration is even less controversial in the case of criminal contempt — even summary contempt — proceedings than in civil contempt because, in addition to incarceration, criminal contempt results in a conviction and cannot be purged by the contemnor. [9] See, e.g., Walker v. McLain, 768 F.2d 1181, 1183 (10th Cir.1985), cert. denied, 474 U.S. 1061 , 106 S.Ct. 805 , 88 L.Ed.2d 781 (1986); Ridgway v. Baker, supra, 720 F.2d at 1413 ; United States v. Johnson, 659 F.2d 415, 416-17 (4th Cir.1

1996I submit that the proposition that there is an entitlement to counsel prior to adjudication resulting in incarceration is even less controversial in the case of criminal contempt — even summary contempt — proceedings than in civil contempt because, in addition to incarceration, criminal contempt results in a conviction and cannot be purged by the contemnor. [9] See, e.g., Walker v. McLain, 768 F.2d 1181, 1183 (10th Cir.1985), cert. denied, 474 U.S. 1061 , 106 S.Ct. 805 , 88 L.Ed.2d 781 (1986); Ridgway v. Baker, supra, 720 F.2d at 1413 ; United States v. Johnson, 659 F.2d 415, 416-17 (4th Cir.1

1996I submit that the proposition that there is an entitlement to counsel prior to adjudication resulting in incarceration is even less controversial in the case of criminal contempt — even summary contempt — proceedings than in civil contempt because, in addition to incarceration, criminal contempt results in a conviction and cannot be purged by the contemnor. [9] See, e.g., Walker v. McLain, 768 F.2d 1181, 1183 (10th Cir.1985), cert. denied, 474 U.S. 1061 , 106 S.Ct. 805 , 88 L.Ed.2d 781 (1986); Ridgway v. Baker, supra, 720 F.2d at 1413 ; United States v. Johnson, 659 F.2d 415, 416-17 (4th Cir.1

1996I submit that the proposition that there is an entitlement to counsel prior to adjudication resulting in incarceration is even less controversial in the case of criminal contempt — even summary contempt — proceedings than in civil contempt because, in addition to incarceration, criminal contempt results in a conviction and cannot be purged by the contemnor. [9] See, e.g., Walker v. McLain, 768 F.2d 1181, 1183 (10th Cir.1985), cert. denied, 474 U.S. 1061 , 106 S.Ct. 805 , 88 L.Ed.2d 781 (1986); Ridgway v. Baker, supra, 720 F.2d at 1413 ; United States v. Johnson, 659 F.2d 415, 416-17 (4th Cir.1

1996For example, in rejecting in-junctive relief to a petitioner evading child-support obligations and seeking counsel to represent him at a contempt hearing, the United States Court of Appeals for the Ninth Circuit noted the decision in Argersinger that had been announced since the initiation of the contempt proceedings, and stated that "[t]he state trial judge, now cognizant of Argersinger , will most assuredly know that if a lawyer is not appointed for [the petitioner's] representation, [the petitioner] cannot be confined even if found to have been contemptuous.” Henkel v. Bradshaw, 483 F.2d 13

1996For example, in rejecting injunctive relief to a petitioner evading child-support obligations and seeking counsel to represent him at a contempt hearing, the United States Court of Appeals for the Ninth Circuit noted the decision in Argersinger that had been announced since the initiation of the contempt proceedings, and stated that "[t]he state trial judge, now cognizant of Argersinger , will most assuredly know that if a lawyer is not appointed for [the petitioner's] representation, [the petitioner] cannot be confined even if found to have been contemptuous." Henkel v. Bradshaw, 483 F.2d 138

1993The Court of Appeals has expressed itself in no uncertain terms with respect to the seriousness of an unexcused failure by an attorney to appear at a scheduled court proceeding, noting that such behavior causes “a loss of valuable time to the court, its personnel, and to every other participant in the trial....” Matter of Alexander, 466 A.2d 447, 450 (D.C.1983).

1990See, e.g., United States v. Meyer, 149 U.S.App.D.C. 212, 222-23 , 462 F.2d 827, 837-38 (1972), discussing restrictions on judge’s right to proceed summarily after the emergency has passed.

1990See, e.g., United States v. Meyer, 149 U.S.App.D.C. 212, 222-23 , 462 F.2d 827, 837-38 (1972), discussing restrictions on judge’s right to proceed summarily after the emergency has passed.

1978See Harrell v. United States, 220 F.2d 516, 520 (5th Cir. 1955).

1978See Harrell v. United States, 220 F.2d 516, 520 (5th Cir. 1955).

1971Sewell v. Trimble, 84 U.S.App.D.C. 193, 193-194 , 172 F.2d 27, 27-28 (1948) ; Diesenhof v. Glass, D.C.Mun.App., 186 A.2d 892, 893 (1962); Darden v. Darden, D.C.Mun.App., 144 A.2d 697, 699 (1958) ; 168 A.L.R. 232 , 234. 5 .

1971Sewell v. Trimble, 84 U.S.App.D.C. 193, 193-194 , 172 F.2d 27, 27-28 (1948) ; Diesenhof v. Glass, D.C.Mun.App., 186 A.2d 892, 893 (1962); Darden v. Darden, D.C.Mun.App., 144 A.2d 697, 699 (1958) ; 168 A.L.R. 232 , 234. 5 .

1971Sewell v. Trimble, 84 U.S.App.D.C. 193, 193-194 , 172 F.2d 27, 27-28 (1948) ; Diesenhof v. Glass, D.C.Mun.App., 186 A.2d 892, 893 (1962); Darden v. Darden, D.C.Mun.App., 144 A.2d 697, 699 (1958) ; 168 A.L.R. 232 , 234. 5 .

1971Sewell v. Trimble, 84 U.S.App.D.C. 193, 193-194 , 172 F.2d 27, 27-28 (1948) ; Diesenhof v. Glass, D.C.Mun.App., 186 A.2d 892, 893 (1962); Darden v. Darden, D.C.Mun.App., 144 A.2d 697, 699 (1958) ; 168 A.L.R. 232 , 234. 5 .