The following excerpt is from Hanshaw v. Emerald River Dev., 244 F.3d 1128 (9th Cir. 2001):
Baldwin v. New York, 399 U.S. 66, 72 (1970) (holding that a defendant who faced a sentence of six months was entitled to a jury trial). This purpose becomes all the more important in the context of criminal contempt or punitive sanctions, wherethe accuser and, in some instances, victim and key witness is the trial judge or, as here, a representative of the court. For the individual accused
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