The following excerpt is from Weiss v. Burr, 484 F.2d 973 (9th Cir. 1973):
See generally United States v. Marshall, 451 F.2d 372 (9th Cir. 1971). A contempt conviction is reversible if the trial judge fails to make adequate factual findings.
Similar rules are in force in most states. See Annot., 154 A.L.R. 1227 (1945).
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