832
Opinion of the Court
a right to jury trial as a protection against the arbitrary exercise of official power." Bloom, 391 U. S., at 202.
Our jurisprudence in the contempt area has attempted to balance the competing concerns of necessity and potential arbitrariness by allowing a relatively unencumbered contempt power when its exercise is most essential, and requiring progressively greater procedural protections when other considerations come into play. The necessity justification for the contempt authority is at its pinnacle, of course, where contumacious conduct threatens a court's immediate ability to conduct its proceedings, such as where a witness refuses to testify, or a party disrupts the court. See Young, 481 U. S., at 820-821 (Scalia, J., concurring in judgment) (the judicial contempt power is a "power of self-defense," limited to sanctioning "those who interfere with the orderly conduct of [court] business or disobey orders necessary to the conduct of that business"). Thus, petty, direct contempts in the presence of the court traditionally have been subject to summary adjudication, "to maintain order in the courtroom and the integrity of the trial process in the face of an 'actual obstruction of justice.' " Codispoti v. Pennsylvania, 418 U. S., at 513, quoting In re McConnell, 370 U. S. 230, 236 (1962); cf. United States v. Wilson, 421 U. S. 309, 315-316 (1975); Harris v. United States, 382 U. S. 162, 164 (1965). In light of the court's substantial interest in rapidly coercing compliance and restoring order, and because the contempt's occurrence before the court reduces the need for extensive factfinding and the likelihood of an erroneous deprivation, summary proceedings have been tolerated.
Summary adjudication becomes less justifiable once a court leaves the realm of immediately sanctioned, petty direct contempts. If a court delays punishing a direct contempt until the completion of trial, for example, due process requires that the contemnor's rights to notice and a hearing be respected. Taylor v. Hayes, 418 U. S. 488 (1974). There "it is much more difficult to argue that action without notice
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