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Moton v. State

The evidence supported the defendant's conviction for criminal contempt arising out of comments he made to several witnesses for the State in the hallway outside of the courtroom where his son was being tried for public indecency.

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Following a hearing, a trial court found Earl M. Moton, Sr., guilty of criminal contempt. On appeal, Moton contends that the evidence was insufficient to support his conviction. For the reasons set forth infra, we affirm.

At the outset, we note that, as with any criminal conviction, “the evidence in any criminal contempt case must show that the defendant is guilty beyond a reasonable doubt.”1 Indeed, criminal contempt is a crime in the ordinary sense; “it is a violation of the law, a public wrong which is punishable by fine or imprisonment or both.”2 And on appeal of a criminal-contempt conviction, the appropriate standard of appellate review is whether, after viewing the evidence in the light most favorable to the prosecution, “any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.”3

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