Dean v. Maryland

Having just been sentenced, and while still standing at the trial table, Timothy Mitchell gave vent to his displeasure by directing a contumelious single-finger gesture at the trial judge. The judge summarily found Mitchell in direct contempt, and sentenced him to an additional term of imprisonment. Mitchell seeks reversal, contending that he was denied due process of law because a summary proceeding was employed, and because the judge who was the object of the insulting gesture conducted the proceeding.