## Facts

- In 1631, a felony defendant in the Court of King’s Bench had already been convicted of a felony.
- During proceedings in open court, the defendant threw a brick at Chief Justice Richardson, narrowly missing him.
- The Chief Justice immediately ordered that the defendant’s hand be cut off.
- The Chief Justice further ordered that the defendant be hanged in the presence of the court.

## Issues

1. What authority did the Court of King’s Bench (or its Chief Justice) have to impose immediate punishment for a violent assault committed in the court’s presence following a felony conviction?
2. Whether the ordered sanctions (mutilation and execution) were imposed as a separate adjudication for the courtroom assault or as a summary incident of the court’s control over proceedings.

## Decision

- The court, through Chief Justice Richardson, directed immediate punishment in response to the in-court assault.
- The court ordered the defendant’s hand to be cut off and then ordered the defendant to be hanged in the court’s presence.

## Legal Principles

- Superior courts claimed and exercised summary power to respond to grave misconduct committed in facie curiae (in the presence of the court), particularly conduct threatening the administration of justice.
- Where a court treated an affront to the bench as an immediate threat to judicial authority and safety, it could order exemplary sanctions without a separately described, ordinary trial process on the record available here.
- The available record does not supply a stated doctrinal test, procedural prerequisites, or articulated reasoning beyond the court’s immediate command.

## Conclusion

The case records an in-court assault on the Chief Justice by a convicted felon and the King’s Bench’s immediate order of mutilation followed by hanging in the court’s presence, illustrating the historical use of summary judicial power to punish direct, violent contempts against the court.


Anonymous, 73 Eng. Rep. 416 n. (K.B. 1631)