The following excerpt is from Davis v. Superior Court of State of Cal., 846 F.2d 1382 (9th Cir. 1988):
1 The four elements required for a finding of contempt set forth in United States v. Seale, 461 F.2d at 366-67, are: (1) the conduct must constitute misbehavior; (2) it must rise to the level of obstructing the administration of justice; (3) it must be in the court's presence; and (4) some form of intent to obstruct justice must be proved.
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