When will a summary contempt citation be issued against an attorney for contempt of court?

However, as we stated in Hawk v. Cardoza, 575 F.2d at 735, an attorney's first amendment and due process rights, and the sixth amendment rights of his client, "must be balanced against the need for order in the trial process. The need for judicial order is not fixed but must be considered in the context of each case. The length of a trial, surrounding controversy, prior warnings from the trial judge and prior conduct of the contemnor are among factors which must be considered in assessing the validity of summary contempt citations."