How not to find somebody guilty of criminal contempt

United States v. Pickering, No. 14-3730 (7th Cir. July 23, 2015).

After Karenza Pickering didn’t show up for federal jury duty, the district court held a contempt hearing. At the hearing, Pickering testified that she had forgotten about the jury summons because she was pregnant and had been shuttling her mother to and from the hospital for treatment. The district court judge, however, found her guilty of willful contempt. The Seventh Circuit now reverses the conviction, observing that the district court’s finding was conclusory and that the government hadn’t elicited any evidence that Pickering willfully disobeyed the jury summons. And the court concludes with a pointed observation: “During the brief hearing,” it says, “the judge seven times addressed the defendant by her first name. Calling a witness, let alone a testifying criminal defendant, by his or her first name is not proper conduct for a judge.”