The following excerpt is from Gustafson, In re, 650 F.2d 1017 (9th Cir. 1981):
Moreover, summary contempt dispenses with the usual guarantees of notice and hearing. Groppi v. Leslie, 404 U.S. 496, 502, 92 S.Ct. 582, 586, 30 L.Ed.2d 632 (1972). We therefore must take special care to ensure that trial judges invoke summary contempt only with careful consideration and good reason.
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