Court of Appeals of Oregon July 5, 2012, CRH080379; A145035 (State v. Spainhower)

BREWER, P. J.

Defendant appeals a judgment imposing a sanction for summary contempt that was entered more than nine months after defendant engaged in the underlying contumacious conduct. He argues that the trial court lacked authority to sanction him for a contempt that was committed in the immediate view and presence of the court after such a lengthy delay.1 We reverse.