## Facts

- S. Edward Bloom was charged in Illinois state court with criminal contempt arising from probate proceedings.
- The contempt involved willfully petitioning to admit to probate a will allegedly prepared and executed after the testator’s death, described as fraud-like, out-of-court misconduct rather than a brief in-court disruption.
- Bloom timely demanded a jury trial; the trial court denied the request.
- A judge, sitting without a jury, found Bloom guilty of criminal contempt and sentenced him to 24 months’ imprisonment.
- The Illinois Supreme Court affirmed the conviction and sentence.

## Issues

1. Whether the Sixth and Fourteenth Amendments require a jury trial in state criminal contempt proceedings when the contempt is “serious.”
2. How to determine whether a criminal contempt is “serious” when the legislature has not fixed a maximum penalty for the offense.
3. Whether recognizing a jury-trial right for serious criminal contempt limits courts’ authority to impose summary sanctions for contempt.

## Decision

- The U.S. Supreme Court reversed and remanded.
- The Court held that criminal contempt is a crime in every essential respect for purposes of the jury-trial guarantees.
- The Court ruled that serious criminal contempts must be tried to a jury upon demand; only petty contempts may be tried without a jury.
- Because Bloom received a two-year prison sentence, the contempt was serious and he was constitutionally entitled to a jury trial.
- The Court stated that its ruling did not affect courts’ power to impose civil contempt sanctions or to punish petty criminal contempts summarily.

## Legal Principles

- Criminal contempt is treated as criminal in nature when it imposes punitive sanctions for past conduct, triggering constitutional protections applicable to criminal prosecutions.
- The Constitution guarantees a jury trial for “serious” offenses; this applies to serious criminal contempt in state courts through the Fourteenth Amendment.
- Only petty criminal contempts may be tried without honoring a demand for a jury trial.
- When no legislative maximum penalty expresses the offense’s seriousness, the best evidence of seriousness is the penalty actually imposed; a two-year sentence is serious.
- Courts retain authority to use summary procedures for petty criminal contempt and to enforce coercive civil contempt remedies.

## Conclusion

The Supreme Court held that serious criminal contempt cannot be adjudicated without a jury when demanded, and that the seriousness of contempt may be measured by the punishment imposed when no statutory maximum exists; Bloom’s two-year sentence therefore required a jury trial.


Bloom v. Illinois, 391 U.S. 194 (1968)