The following excerpt is from U.S. v. Gracia, 755 F.2d 984 (2nd Cir. 1985):
Appellants are also mistaken in thinking that current law fails to provide adequate due process protections simply because contempt penalties are limited only by judicial discretion. To guard against abuse in contempt sentences, both district and circuit courts must exercise special responsibilities. Green v. United States, 356 U.S. 165, 188, 78 S.Ct. 632, 645, 2 L.Ed.2d 672 (1958), partially overruled on other grounds, Bloom v. Illinois, 391 U.S. 194, 88 S.Ct. 1477, 20 L.Ed.2d 522 (1968).
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