COURT OF APPEALS OF VIRGINIA
Present: Chief Judge Decker, Judge AtLee and Senior Judge Humphreys UNPUBLISHED
Argued at Williamsburg, Virginia
COREY SALMON MEMORANDUM OPINION* BY v. Record No. 1276-24-1 CHIEF JUDGE MARLA GRAFF DECKER JANUARY 20, 2026 COMMONWEALTH OF VIRGINIA
FROM THE CIRCUIT COURT OF THE CITY OF PORTSMOUTH Johnny E. Morrison, Judge
Althea L. Mease, Public Defender, for appellant.
Timothy J. Huffstutter, Assistant Attorney General (Jason S. Miyares,1 Attorney General, on brief), for appellee.
This case originates from actions in the presence of the trial court. During his jury trial
for maliciously shooting into an occupied vehicle, the trial court discovered that Corey Lamar
Salmon continued using his smart watch after being told to stop by the courtroom deputy and
that he was recording the trial on his cell phone without court approval. Salmon admitted to
recording the proceedings, despite earlier admonitions by the court about the use of electronics.
The court declared a mistrial, citing concerns for the jurors and the witnesses, and convicted
Salmon of contempt of court. Salmon was sentenced to five days in jail, all suspended, and fined
$25. On appeal, he argues that the trial court erred in finding the evidence sufficient to convict
him of direct contempt. Finding no error, we affirm the trial court’s judgment.
* This opinion is not designated for publication. See Code § 17.1-413(A). 1 Jay C. Jones succeeded Jason S. Miyares as Attorney General on January 17, 2026. BACKGROUND2
Salmon was on trial for maliciously shooting into an occupied vehicle. He elected to be
tried by a jury, and the panel was selected. Following the testimony of the prosecution’s last
witness, the court sent the jury from the courtroom. The judge stated he noticed that the
courtroom deputy had “talked to th[e] defendant a couple [of] times” during the case. Deputy
Ruiz advised the court that he saw Salmon “scrolling through his smart watch” twice, which was
“the equivalent of using his cell phone.” According to the deputy, he told Salmon not to use his
smart watch after the first observation. But after that, Ruiz saw Salmon scrolling again. The
deputy explained that when he confronted Salmon the second time, Salmon said he was “texting
his lawyer.” He then clarified that he “was showing a message to [his] lawyer” and claimed it
did not constitute texting. At that point, the judge admonished Salmon that he was “not to use
any kind of equipment in th[e] courtroom” and that his smart watch was the equivalent of his
phone. Salmon acknowledged that he understood, and the judge directed him to give his cell
phone and smart watch to Deputy Ruiz.
After this exchange, the Commonwealth rested its case, and Salmon moved to strike the
evidence, which the trial court denied. Salmon presented evidence and testified in his defense.
After the defense rested, the judge called on the deputy again. The deputy relayed that, as
Salmon was testifying, his cell phone lit up and it “appear[ed] . . . Salmon ha[d] been [audio]
recording th[e] trial for 1 hour 46 minutes and 53 seconds.” When asked, Salmon admitted that
he knew his phone was recording and added that he had not told his attorneys. The court
2 On appeal, this Court recites the facts “in the ‘light most favorable’ to the Commonwealth, the prevailing party in the trial court.” Hammer v. Commonwealth, 74 Va. App. 225, 231 (2022) (quoting Commonwealth v. Cady, 300 Va. 325, 329 (2021)). In doing so, we discard any evidence that conflicts with the Commonwealth’s evidence, “and regard as true all the credible evidence favorable to the Commonwealth and all . . . inferences” that can be fairly drawn from that evidence. Cady, 300 Va. at 329 (quoting Commonwealth v. Perkins, 295 Va. 323, 324 (2018) (per curiam)). -2- explained that no one was permitted to “record anything in this courtroom, even the press. They
have to get permission of the [c]ourt.” Salmon said that he was “ignorant” and did not know that
he needed to ask for permission to record the proceedings. He argued that no signs prohibited
recording.
The trial court expressed its concern for the jurors and the witnesses who had testified. It
admonished Salmon and pointed out that there were signs posted throughout the building
“dealing with” recordings and photographs. Ultimately, the court declared a mistrial, mainly out
of concern for the safety of “the jury and [the] witnesses” and because the court did not know
Salmon’s motive behind recording. It held Salmon in contempt, issued a show cause order with
a 15-day return, and confiscated his watch and cell phone.
At the show cause hearing, Salmon presented evidence in his defense. He introduced
photos of signs that were posted at the two main entrances to the courthouse. The signs listed
items banned “[b]y court order.” Cameras and video equipment and certain non-electronic items
were listed as prohibited. Salmon testified that he did not know why he was there and did not
“know what the fuck [wa]s going on.” According to Salmon, he did not know of a reason he was
not permitted to record the trial, he heard no announcements telling him not to record, and he
saw no signs against recording. Salmon again explained his thought process about recording the
proceedings and noted he wanted his own record of the trial because he did not trust anyone and
did not understand legal terms. He denied any intention to disrespect the court or use the
information he gained about the jurors. On cross-examination, Salmon was asked if he
remembered the deputy “telling [him] to turn off [his] devices when [Deputy Ruiz] caught [him]
on [his] watch.” Salmon responded affirmatively and further agreed that he did not follow the
deputy’s directive.
-3- Salmon argued he did not intend to disrespect the court and his actions did not directly
“disregard” “any rule, policy, posted sign, [or] announcement” that “got to him.” The trial court
reiterated, as it did the day of the jury trial, that Salmon had been told twice by the deputy not to
use his smart watch yet kept using it and then was found to be recording. It held Salmon in
contempt of court under Code § 18.2-456(A)(1), sentenced him to five days in jail, all
suspended, and imposed a $25 fine.
ANALYSIS
Salmon challenges the sufficiency of the evidence to support his conviction. He contends
that based on the evidence his actions did not amount to the requisite willful intent. He also
argues that there is “limited information on the record” clearly identifying which facts the court
relied on in support of its decision.
An appellate court will “review the exercise of a court’s contempt power under an abuse
of discretion standard.” Orndoff v. Commonwealth, ___ Va. ___, ___ (Sept. 25, 2025) (plurality
opinion) (quoting Petrosinelli v. People for the Ethical Treatment of Animals, Inc., 273 Va. 700,
706 (2007)); see also Sapp v. Commonwealth, 263 Va. 415, 425 (2002) (noting that the “use of
contempt powers is clearly subject to the discretion of the trial court”). “This bell-shaped curve
of reasonability” underpinning appellate review for an abuse of discretion “rests on the venerable
belief that the judge closest to the contest is the judge best able to discern where the equities lie.”
Commonwealth v. Barney, 302 Va. 84, 94 (2023) (quoting Sauder v. Ferguson, 289 Va. 449, 459
(2015)).
Free access — add to your briefcase to read the full text and ask questions with AI
COURT OF APPEALS OF VIRGINIA
Present: Chief Judge Decker, Judge AtLee and Senior Judge Humphreys UNPUBLISHED
Argued at Williamsburg, Virginia
COREY SALMON MEMORANDUM OPINION* BY v. Record No. 1276-24-1 CHIEF JUDGE MARLA GRAFF DECKER JANUARY 20, 2026 COMMONWEALTH OF VIRGINIA
FROM THE CIRCUIT COURT OF THE CITY OF PORTSMOUTH Johnny E. Morrison, Judge
Althea L. Mease, Public Defender, for appellant.
Timothy J. Huffstutter, Assistant Attorney General (Jason S. Miyares,1 Attorney General, on brief), for appellee.
This case originates from actions in the presence of the trial court. During his jury trial
for maliciously shooting into an occupied vehicle, the trial court discovered that Corey Lamar
Salmon continued using his smart watch after being told to stop by the courtroom deputy and
that he was recording the trial on his cell phone without court approval. Salmon admitted to
recording the proceedings, despite earlier admonitions by the court about the use of electronics.
The court declared a mistrial, citing concerns for the jurors and the witnesses, and convicted
Salmon of contempt of court. Salmon was sentenced to five days in jail, all suspended, and fined
$25. On appeal, he argues that the trial court erred in finding the evidence sufficient to convict
him of direct contempt. Finding no error, we affirm the trial court’s judgment.
* This opinion is not designated for publication. See Code § 17.1-413(A). 1 Jay C. Jones succeeded Jason S. Miyares as Attorney General on January 17, 2026. BACKGROUND2
Salmon was on trial for maliciously shooting into an occupied vehicle. He elected to be
tried by a jury, and the panel was selected. Following the testimony of the prosecution’s last
witness, the court sent the jury from the courtroom. The judge stated he noticed that the
courtroom deputy had “talked to th[e] defendant a couple [of] times” during the case. Deputy
Ruiz advised the court that he saw Salmon “scrolling through his smart watch” twice, which was
“the equivalent of using his cell phone.” According to the deputy, he told Salmon not to use his
smart watch after the first observation. But after that, Ruiz saw Salmon scrolling again. The
deputy explained that when he confronted Salmon the second time, Salmon said he was “texting
his lawyer.” He then clarified that he “was showing a message to [his] lawyer” and claimed it
did not constitute texting. At that point, the judge admonished Salmon that he was “not to use
any kind of equipment in th[e] courtroom” and that his smart watch was the equivalent of his
phone. Salmon acknowledged that he understood, and the judge directed him to give his cell
phone and smart watch to Deputy Ruiz.
After this exchange, the Commonwealth rested its case, and Salmon moved to strike the
evidence, which the trial court denied. Salmon presented evidence and testified in his defense.
After the defense rested, the judge called on the deputy again. The deputy relayed that, as
Salmon was testifying, his cell phone lit up and it “appear[ed] . . . Salmon ha[d] been [audio]
recording th[e] trial for 1 hour 46 minutes and 53 seconds.” When asked, Salmon admitted that
he knew his phone was recording and added that he had not told his attorneys. The court
2 On appeal, this Court recites the facts “in the ‘light most favorable’ to the Commonwealth, the prevailing party in the trial court.” Hammer v. Commonwealth, 74 Va. App. 225, 231 (2022) (quoting Commonwealth v. Cady, 300 Va. 325, 329 (2021)). In doing so, we discard any evidence that conflicts with the Commonwealth’s evidence, “and regard as true all the credible evidence favorable to the Commonwealth and all . . . inferences” that can be fairly drawn from that evidence. Cady, 300 Va. at 329 (quoting Commonwealth v. Perkins, 295 Va. 323, 324 (2018) (per curiam)). -2- explained that no one was permitted to “record anything in this courtroom, even the press. They
have to get permission of the [c]ourt.” Salmon said that he was “ignorant” and did not know that
he needed to ask for permission to record the proceedings. He argued that no signs prohibited
recording.
The trial court expressed its concern for the jurors and the witnesses who had testified. It
admonished Salmon and pointed out that there were signs posted throughout the building
“dealing with” recordings and photographs. Ultimately, the court declared a mistrial, mainly out
of concern for the safety of “the jury and [the] witnesses” and because the court did not know
Salmon’s motive behind recording. It held Salmon in contempt, issued a show cause order with
a 15-day return, and confiscated his watch and cell phone.
At the show cause hearing, Salmon presented evidence in his defense. He introduced
photos of signs that were posted at the two main entrances to the courthouse. The signs listed
items banned “[b]y court order.” Cameras and video equipment and certain non-electronic items
were listed as prohibited. Salmon testified that he did not know why he was there and did not
“know what the fuck [wa]s going on.” According to Salmon, he did not know of a reason he was
not permitted to record the trial, he heard no announcements telling him not to record, and he
saw no signs against recording. Salmon again explained his thought process about recording the
proceedings and noted he wanted his own record of the trial because he did not trust anyone and
did not understand legal terms. He denied any intention to disrespect the court or use the
information he gained about the jurors. On cross-examination, Salmon was asked if he
remembered the deputy “telling [him] to turn off [his] devices when [Deputy Ruiz] caught [him]
on [his] watch.” Salmon responded affirmatively and further agreed that he did not follow the
deputy’s directive.
-3- Salmon argued he did not intend to disrespect the court and his actions did not directly
“disregard” “any rule, policy, posted sign, [or] announcement” that “got to him.” The trial court
reiterated, as it did the day of the jury trial, that Salmon had been told twice by the deputy not to
use his smart watch yet kept using it and then was found to be recording. It held Salmon in
contempt of court under Code § 18.2-456(A)(1), sentenced him to five days in jail, all
suspended, and imposed a $25 fine.
ANALYSIS
Salmon challenges the sufficiency of the evidence to support his conviction. He contends
that based on the evidence his actions did not amount to the requisite willful intent. He also
argues that there is “limited information on the record” clearly identifying which facts the court
relied on in support of its decision.
An appellate court will “review the exercise of a court’s contempt power under an abuse
of discretion standard.” Orndoff v. Commonwealth, ___ Va. ___, ___ (Sept. 25, 2025) (plurality
opinion) (quoting Petrosinelli v. People for the Ethical Treatment of Animals, Inc., 273 Va. 700,
706 (2007)); see also Sapp v. Commonwealth, 263 Va. 415, 425 (2002) (noting that the “use of
contempt powers is clearly subject to the discretion of the trial court”). “This bell-shaped curve
of reasonability” underpinning appellate review for an abuse of discretion “rests on the venerable
belief that the judge closest to the contest is the judge best able to discern where the equities lie.”
Commonwealth v. Barney, 302 Va. 84, 94 (2023) (quoting Sauder v. Ferguson, 289 Va. 449, 459
(2015)).
A trial court’s exercise of its discretion to find someone in contempt differs from the
question of whether the record supports such a conviction. In these matters where the
sufficiency of the evidence is challenged, appellate courts “will reverse a judgment of the circuit
court only upon a showing that it is plainly wrong or without evidence to support it.” Singleton
-4- v. Commonwealth, 278 Va. 542, 548 (2009). A reviewing court simply will “not substitute its
judgment for that of the trier of fact” on matters of sufficiency of the evidence. Becker v.
Commonwealth, 64 Va. App. 481, 490 (2015) (quoting Robinson v. Commonwealth, 41 Va. App.
137, 142 (2003)). “[I]t is not for this [C]ourt to say that the evidence does or does not establish
[the defendant’s] guilt beyond a reasonable doubt because as an original proposition it might
have reached a different conclusion.” Barney, 302 Va. at 97 (second and third alterations in
original) (quoting Cobb v. Commonwealth, 152 Va. 941, 953 (1929)). Instead, the question on
appeal is “whether any rational trier of fact could have found the [challenged] elements of the
crime beyond a reasonable doubt.” Cappe v. Commonwealth, 304 Va. 86, 87 (2025) (per
curiam) (emphasis added) (quoting Sullivan v. Commonwealth, 280 Va. 672, 676 (2010)). We
apply this well-established standard of review when considering Salmon’s challenge to the
sufficiency of the evidence of his conviction for contempt.
“Virginia courts have long recognized that the ‘power to punish for contempt is inherent
in, and as ancient as, courts themselves.’” Parham v. Commonwealth, 60 Va. App. 450, 455
(2012) (quoting Carter v. Commonwealth, 2 Va. App. 392, 395 (1986)). This power is necessary
based “on the basic need to ‘preserve the confidence and respect of the people.’” Id. at 455-56
(quoting Carter, 2 Va. App. at 395); see also Gilman v. Commonwealth, 275 Va. 222, 227
(2008) (stating that contempt powers are “exercised to preserve the power of the court and to
vindicate the court’s dignity”). Courts should use this power “[t]o preserve order in the court
room for the proper conduct of business.” Cooke v. United States, 267 U.S. 517, 534 (1925).
And carrying out this directive requires that “court[s] . . . act instantly to suppress disturbance[s]
or violence or physical obstruction[s] or disrespect to the court when occurring in open court.”
Id. The law makes clear the unique nature of contempt crimes.
-5- Based on these principles, “[i]t is [considered] elementary that any act which is calculated
to embarrass, hinder, or obstruct the court in the administration of justice is contempt.” Parham,
60 Va. App. at 456 (first alteration in original) (quoting Potts v. Commonwealth, 184 Va. 855,
859 (1946)). Stated differently, “[c]ontempt under Virginia law is ‘“an act in disrespect of the
court or its processes, or which obstructs the administration of justice, or tends to bring the court
into disrepute.”’” Abdo v. Commonwealth, 64 Va. App. 468, 476 (2015) (quoting Robinson, 41
Va. App. at 142). It “‘is, itself, a frame of mind’ that consists in ‘an unwillingness to recognize
the authority and dignity of the court.’” Becker, 64 Va. App. at 490 (quoting Abdo, 64 Va. App.
at 477). Code § 18.2-456(A)(1) provides courts the statutory authority to punish such
“[m]isbehavior in the presence of the court, or so near thereto as to obstruct or interrupt the
administration of justice.”3
“A ‘direct contempt is one committed in the presence of the court.’”4 Bell v.
Commonwealth, 81 Va. App. 616, 625 (2024) (quoting Gilman, 275 Va. at 227). This species of
contempt allows “the judge [to be] his own best witness of what occurred.” Scialdone v.
Commonwealth, 279 Va. 422, 444 (2010) (quoting United States v. Marshall, 451 F.2d 372, 374
(9th Cir. 1971)). And because the act “is committed in the presence of the court, it is competent
for it to proceed upon its own knowledge of the facts, ‘and to punish the offender without further
3 The term “misbehavior” is not defined because “[i]t is assumed that reasonable people understand the line between good and bad behavior, particularly when exhibited in open court in the presence of a judge.” Parham, 60 Va. App. at 459. 4 “[T]here are two distinct types of contempt, direct and indirect.” Scialdone v. Commonwealth, 279 Va. 422, 442 (2010). “Indirect contempt” occurs outside “‘the presence of the court.’” Id. at 443 (quoting Burdett v. Commonwealth, 103 Va. 838, 846 (1904)). -6- proof, and without issue or trial in any form.’”5 Robinson, 41 Va. App. at 145 (quoting Burdett
v. Commonwealth, 103 Va. 838, 845-46 (1904)). This offense is also referred to as summary
contempt. See Amos v. Commonwealth, 61 Va. App. 730, 742 (2013) (en banc) (discussing “the
exercise of the summary or direct contempt power”), aff’d, 287 Va. 301 (2014). “[S]ummary
vindication” is “justif[ied]” in these circumstances because “the affront to the court’s dignity is
more widely observed,” and its authority needs to be preserved. Parham, 60 Va. App. at 457-58
(2012) (quoting Pounders v. Watson, 521 U.S. 982, 988 (1997) (per curiam)).
Salmon challenges the proof of his intent. Important to our analysis is that “[w]hether the
required intent exists is generally a question for the trier of fact.” Becker, 64 Va. App. at 491
(quoting Nobles v. Commonwealth, 218 Va. 548, 551 (1977)). The general definition of intent is
well understood. “Intent is the purpose formed in a person’s mind and may, like any other fact,
be shown by circumstances, including the ‘words or conduct’ of the alleged offender.” Fary v.
Commonwealth, 77 Va. App. 331, 342 (2023) (en banc) (quoting Secret v. Commonwealth, 296
Va. 204, 228-29 (2018)), aff’d per curiam, 303 Va. 1 (2024); see also Abdo, 64 Va. App. at 475.
“[W]illfulness or recklessness satisfies the intent element necessary for a finding of
criminal contempt.” Becker, 64 Va. App. at 491 (quoting Abdo, 64 Va. App. at 477). As such,
the offender does not have to have a specific intent “to disrupt court proceedings.” Abdo, 64
Va. App. at 478. This Court has stated that a willful intent in the context of a criminal statute
“generally means an act done with a bad purpose; without justifiable excuse; stubbornly,
5 “[T]he substantial difference between a direct and [indirect] contempt is one of procedure.” Parham, 60 Va. App. at 457 (second alteration in original) (quoting Burdett, 103 Va. at 845). Since indirect contempt occurs outside the court’s presence, “due process ‘requires that the accused should be advised of the charges and have a reasonable opportunity to meet them by way of defense or explanation.’” Scialdone, 279 Va. at 444 (quoting Cooke, 267 U.S. at 537). Even though Salmon’s actions occurred in the presence of the trial court, he was still provided a hearing and was allowed to present additional evidence. As his counsel appropriately acknowledged at oral argument in this Court, Salmon was given more “process” than he was entitled to under the law. -7- obstinately, perversely[.]” Id. at 477 (alteration in original) (quoting Barrett v. Commonwealth,
268 Va. 170, 183 (2004)). “The term ‘willful act’ imports knowledge and consciousness that
injury will result from the act done,” and the act “must be intended or . . . involve a reckless
disregard for the rights of another and will probably result in an injury.” Id. (quoting Barrett,
268 Va. at 183).
On this record, there is sufficient evidence that Salmon acted willfully or recklessly in the
use of his smart watch and cell phone during his jury trial. Signs at the entrances to the court
clearly prohibited the use of cameras and video equipment, which at minimum informed Salmon
there were limitations on the use of electronic devices. More importantly, he was told twice not
to use his smart watch while in the courtroom, and he acknowledged that he did not turn off his
devices as instructed by the deputy. The trial court had to disrupt the trial and remove the jury to
find out why the deputy had to speak to Salmon. See Amos, 61 Va. App. at 742 (discussing that
direct contempt “is reserved for ‘“exceptional circumstances” . . . [like] disrupting a hearing or
obstructing court proceedings’” (quoting Vaughn v. City of Flint, 752 F.2d 1160, 1167 (6th Cir.
1985))). The court then directed that Salmon was not allowed to “use any kind of equipment in
th[e] courtroom.” Salmon said he understood and apologized. The trial court instructed the
deputy to take his smart watch and phone away from him.
Despite the clear admonitions and the confiscation of the items, Salmon knowingly
allowed the audio recording of the proceeding to continue and did not inform the court until after
the deputy noticed that the cell phone was recording the trial and had been doing so for almost
two hours. See Robinson, 41 Va. App. at 144 (considering an attorney’s failure to alert the court
“of his tardiness” in the analysis affirming the sufficiency of the evidence). Despite having been
told the use of any equipment was prohibited, Salmon claimed that he did not realize that
-8- recording would be an issue and that he had no ill intent motivating his actions.6 See id. at 143
(holding that “assertions of good faith ‘d[id] not negate the reasonable inference’” supporting a
finding of the requisite intent for contempt (quoting Murphy v. Maryland, 416 A.2d 748, 756
n.11 (Md. Ct. Spec. App. 1980))).
In the end, the trial judge, who had the benefits of being present for the acts and hearing
the evidence, reasonably concluded that Salmon’s repeated actions were clearly done “without
justifiable excuse; stubbornly, obstinately, [or] perversely[.]” Barrett, 268 Va. at 183 (second
alteration in original) (quoting United States v. Murdock, 290 U.S. 389, 394 (1933)). And they
showed he had “an unwillingness to recognize the authority and dignity of the court.” Becker, 64
Va. App. at 490 (quoting Abdo, 64 Va. App. at 477).
This record supports the trial court’s factual finding that Salmon willfully or recklessly
disrupted the court’s proceedings, and his assertions of ignorance “[do] not negate the reasonable
inference” he had such intent. Robinson, 41 Va. App. at 143 (alteration in original) (quoting
Murphy, 416 A.2d at 756 n.11).
Finally, Salmon cites the proposition that to support a conviction for direct contempt,
“[t]he record . . . must contain more than the bare conclusion that the defendant’s conduct was”
contemptuous. Carter, 2 Va. App. at 397. He suggests that the court did not articulate the clear
basis for its contempt finding. We disagree.
A trial court finding someone in contempt, especially direct contempt, “should recite the
facts upon which” it “base[s] its final conclusion.” Id. (quoting 17 Am. Jur. 2d Contempt § 100
(1964)). Still, even without this recitation, a conviction for contempt will be upheld as long as
the “record . . . contains the evidence to support the conclusions of the trial court.” Id. at 399.
6 “The factfinder need not believe an accused’s explanation and . . . may infer that the accused is lying to conceal his guilt.” Abdo, 64 Va. App. at 479 n.5 (quoting Phan v. Commonwealth, 258 Va. 506, 511 (1999)). -9- Here, a review of the record shows the trial court clearly identified the contemptuous
conduct. On the day of the jury trial, the court stated that Salmon had been told twice not to use
his smart watch. The deputy spoke with him once, and Salmon “didn’t listen” and then did the
same thing again. After that, the deputy discovered that he had been audio recording the trial on
his phone, which caused the court great concern. These facts supported the court’s initial finding
of summary contempt. At the conclusion of the show-cause hearing, the trial court affirmed its
contempt finding. In doing so, it referred back to the statements it made on the day of the
aborted jury trial in support of its decision. Even still, it considered in its ruling Salmon’s
testimony at the show-cause hearing and the foul language he had used. The court reiterated that
Salmon had been warned by the deputy not to use his smart watch but “proceeded to keep doing
it” along with recording the trial. The record supports the trial court’s factual findings and
contains “more than . . . bare conclusion[s]” of Salmon’s offending conduct by providing several
instances where he acted in a manner that disrupted the court proceedings that ultimately
required ending in a mistrial. See id.
We hold, viewing the evidence in the light most favorable to the Commonwealth, that a
rational fact finder could find that Salmon willfully or recklessly disrupted court proceedings.
As a result, his actions constituted “[m]isbehavi[ng] in the presence of the court” in such a
manner “as to obstruct or interrupt the administration of justice.” See Code § 18.2-456(A)(1).
Accordingly, the evidence was sufficient to convict Salmon of contempt of court.
CONCLUSION
For these reasons, the trial court did not abuse its discretion in holding Salmon in direct
contempt, and there was sufficient evidence on the record that he willfully or recklessly
- 10 - disrupted court proceedings by continuing to use his electronic equipment within the courtroom.
We therefore affirm the judgment of the trial court.
Affirmed.
- 11 -