Connecticut General Statutes

Conn. Gen. Stat. § 51-33 (2026)

Punishment for contempt of court

✓ current as of May 2026

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Any court, including a family support magistrate, may punish by fine and imprisonment any person who in its presence behaves contemptuously or in a disorderly manner; but no court or family support magistrate may impose a greater fine than one hundred dollars or a longer term of imprisonment than six months or both.

(1949 Rev., S. 7702; 1959, P.A. 28, S. 82; P.A. 82-248, S. 16; P.A. 89-360, S. 19, 45.)

History: 1959 act deleted provision that justice of the peace is not to inflict fine of more than $7 or term of imprisonment greater than 30 days; P.A. 82-248 changed “shall inflict” to “may impose” and added “or both” after “months”; P.A. 89-360 added references to family support magistrates.

Section does not apply to contempts by disobedience to the decrees of a court of chancery. 38 C. 121; 102 C. 357. Punishment of contempt by fine and imprisonment is not properly a criminal proceeding; statute applies to courts created after its passage. 43 C. 267. The power to punish for contempt is inherent in all courts, independently of statute law. Id., 268. When adjudication of contempt not reviewable. 44 C. 409. Contempts not committed in the presence of the court are to be ascertained and punished according to the common law. 48 C. 196; 52 C. 156. What constitutes a civil and what a criminal contempt. Id., 155; 147 C. 167. Contempt distinguished from power to commit witnesses for refusal to answer. 65 C. 32. Power of justice to punish for contempt not committed in his presence, quaere. 75 C. 350. Court having no criminal jurisdiction may punish for contempt. 80 C. 671. To deceive court by untruthful statements as to purpose of offering testimony is a contempt. 84 C. 62. Applies to town courts. 82 C. 265. Nature of proceedings and procedure in general. Id., 262; 84 C. 60. Judgment should contain the facts upon which conclusion of contempt is based; criminal contempt held not to constitute true criminal offense. 147 C. 167. Held that contemptuous statements in writing submitted to the court can constitute a contempt in the presence of the court; even if warning given the accused by the court could be distorted into an adjudication that he would not be found in contempt, that adjudication remained subject to change during the course of the trial; statements made in a motion for disqualification of a judge held to constitute a contempt of court. 148 C. 77. As long as punishment is kept within the prescribed term, the court's jurisdiction to impose such punishment summarily is clear and does not offend due process guarantees; section neither expressly nor impliedly repealed by Sec. 51-33a, both are operative. 186 C. 256. Where contemptuous conduct is committed in the presence of the court, punishment may be announced summarily and a writ of error is the sole method to review such a summary criminal contempt citation. 189 C. 663, 666. Cited. 191 C. 110; 197 C. 566; 207 C. 456; 214 C. 344. Trial court authorized to sentence plaintiff to an aggregate sentence greater than 6 months based on 3 separate incidents of contemptuous conduct. 221 C 498. Cited. 222 C. 591; 225 C. 355; 230 C. 698; 241 C. 569. Trial court improperly determined plaintiff could no longer invoke privilege against self-incrimination and improperly held him in contempt for refusing to answer questions at the criminal trial of codefendant based on plaintiff's previous waiver of the privilege at his own criminal trial. 259 C. 487.

Court is authorized to impose sentence of 6 months' imprisonment for criminal contempt where defendant's use of profanity in open court disrupts court proceedings, reflects disobedience to court's order to be silent and imposes an indignity on authority of the court. 88 CA 599.

Contempt in constructive presence of court discussed. 36 CS 547. Until trial court's summary adjudication of contempt is challenged by writ of error, a presumption of finality is accorded to trial judge's exercise of discretion in dealing with contemptuous conduct in his presence. Id., 550.

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Notes of Decisions

Cited in 27 cases, 1960–2017 · leading case: Ullmann v. State, 647 A.2d 324 (Conn. 1994).

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Ullmann v. State, 647 A.2d 324 (Conn. 1994). · cites it 17× “Ullmann (plaintiff), was held in criminal contempt by the trial court pursuant to General Statutes § 51-33 1 for refusing to testify in a criminal trial.”

Rowe v. Superior Court, Jud. Dist. of New Haven, 960 A.2d 256 (Conn. 2008). · cites it 18× “The plaintiff in error, Lamar Rowe (plaintiff), brings this writ of error seeking reversal in part of the trial court's summary judgment of criminal contempt rendered pursuant to General Statutes § 51-33. [1] He contends that the trial court improperly found that he had…”

Vasquez v. Superior Court, 925 A.2d 1112 (Conn. App. Ct. 2007). · cites it 33× “The primary issue posed by the plaintiff in error, Juan Vasquez (the plaintiff), in connection with his writ of error, 1 is whether the trial judge, before *396 whom the allegedly contemptuous behavior had occurred, could punish him for summary criminal contempt pursuant to…”

Wilson v. Cohen, 610 A.2d 1177 (Conn. 1992). · cites it 19× “The trial court reviewed General Statutes §§ 51-33, 51-33a and 51-35.”

Martin v. Flanagan, 789 A.2d 979 (Conn. 2002). · cites it 6× “The dispositive issue in this writ of error is whether, pursuant to General Statutes § 51-33, 1 the trial court improperly rejected the assertion by the plaintiff in error, Carlton Martin (plaintiff), of his fifth amendment privilege not to testify and improperly held him in…”

Banks v. Thomas, 698 A.2d 268 (Conn. 1997). · cites it 6× “General Statutes §§ 51-33 and 51-33a and Practice Book §§ 985, 986 and 988 set forth the procedures applicable to criminal contempt proceedings.”

Naunchek v. Naunchek, 463 A.2d 603 (Conn. 1983). · cites it 11× “1 The trial court held the plaintiff in contempt of court under General Statutes § 51-33 2 because of her statements during the course of the trial.”

Moore v. State, 440 A.2d 969 (Conn. 1982). · cites it 8× “The writ raises three issues, namely, (1) whether the plaintiff’s conduct constituted a contempt, (2) *257 whether the plaintiff had a right to be tried pursuant to the provisions of General Statutes § 51-33a, and (3) if General Statutes § 51-33 is the applicable statute,…”

Furs v. Superior Court, 3 A.3d 912 (Conn. 2010). · cites it 9× “When the plaintiff refused to do so and claimed his fifth amendment privilege against self-incrimination, the court found the plaintiff in contempt *410 of court in violation of General Statutes § 51-33, 6 and sentenced him to a term of six months imprisonment, consecutive to…”

Jackson v. Bailey, 605 A.2d 1350 (Conn. 1992). · cites it 6× “Pursuant to General Statutes § 51-33, “[a]ny court . .”

McClain v. Robinson, 457 A.2d 1072 (Conn. 1983). · cites it 5× “Melechinsky, supra, 549 ; see General Statutes § 51-33. 5 Under such circumstances, “ ‘no witnesses are required in proof of the contempt, and the eourt has inherent power to impose punishment on its own knowledge and of its own motion without formal presentation or hearing of…”

Higgins v. Liston, 870 A.2d 1137 (Conn. App. Ct. 2005). · cites it 8× “See General Statutes § 51-33. 6 *610 The plaintiff in error claims that a right to counsel exists because a summary criminal contempt proceeding is a criminal prosecution for a criminal offense, to which the right to counsel clearly applies.”

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