In re Deters

2020 Ohio 3518
CourtOhio Court of Appeals
DecidedJune 30, 2020
DocketC-190516
StatusPublished
Cited by3 cases

This text of 2020 Ohio 3518 (In re Deters) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Deters, 2020 Ohio 3518 (Ohio Ct. App. 2020).

Opinion

[Cite as In re Deters, 2020-Ohio-3518.] IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

IN RE: ERIC DETERS : APPEAL NO. C-190516 TRIAL NO. M-1900912

: O P I N I O N.

Criminal Appeal From: Hamilton County Court of Common Pleas

Judgment Appealed From Is: Affirmed

Date of Judgment Entry on Appeal: June 30, 2020

Schroeder, Maundrell, Barbiere & Powers, Lawrence E. Barbiere and Katherine L. Barbiere, for Appellee Honorable Mark R. Schweikert,

Robert A. Winter, Jr., The Deters Law Firm Co. II, P.A., James F. Maus and Shawn Crawford, for Appellant Eric Deters. OHIO FIRST DISTRICT COURT OF APPEALS

C ROUSE , Judge.

{¶1} Defendant-appellant Eric Deters appeals the trial court’s judgment

finding him in contempt of court. For the reasons set forth below, we affirm the

judgment of the trial court.

Facts and Procedure

{¶2} In August 2017, the Ohio Supreme Court appointed appellee retired

Judge Mark Schweikert to preside over the multitude of medical-malpractice cases

involving Abubakar Atiq Durrani, M.D. The Deters Law Firm, with whom Deters is

employed, represents a large number of the plaintiffs in the Durrani cases.

{¶3} On April 27, 2018, all persons involved with the Durrani litigation agreed

to a gag order which generally prohibited public discussion of the Durrani cases and

their merits. The order came about as a means of settling a prior contempt motion filed

against Deters by the defendants in the Durrani cases. In January 2019, the defendants

again sought contempt charges against Deters for alleged violations of the April 2018

order. The trial court held a hearing on the motion on March 22, 2019. At the March 22

hearing, the court instructed Deters to come into compliance with the gag order

immediately and admonished him for his “foolish antics.” Deters assured the court that

he would follow the order. As a means of again settling the contempt allegations, all

parties and their agents entered into a second gag order.

{¶4} The second order specifically prohibited “discussing, or posting

information about, the cases and their merits with the general public through written or

electronic media, the Internet, including social media, blogs, and similar media formats

in any form.” The order also forbade “participat[ing] in interviews with the media

and/or from making public statements generally, including public demonstrations

regarding the pending cases.” It further ordered the removal of “content posted on any

2 OHIO FIRST DISTRICT COURT OF APPEALS

website and/or social media platform which is in violation of this Order[.]” By its terms,

the order applied to “all parties to the pending cases, their counsel, employees, agents,

and witnesses.”

{¶5} Following a case-management conference on August 6, 2019, the trial

court denied the Durrani plaintiffs’ request for group trials. In response to the August 6

order, Deters planned to issue a public comment to protest Judge Schweikert’s handling

of the Durrani cases. Upon learning of the planned comment, the court immediately

issued a notice to Deters, stating: “[T]o the extent that any such activity is a violation of

this Court’s previous orders to refrain from public comment regarding [the Durrani]

proceedings, and if the acts are observed by the Court, the Hamilton County Sheriff or

other officer of this Court, this Court will treat such act as a Direct Contempt subject to

possible incarceration[.]” The following day, Deters presented his public comment on

the Hamilton County Courthouse steps. Judge J. Howard Sundermann (acting on

behalf of Judge Schweikert), members of the Hamilton County Sheriff’s Office, some of

the plaintiffs in the Durrani cases, and local news reporters were present.

{¶6} A week later, the trial court issued a show-cause order. The order

instructed Deters to appear before the court on September 3, 2019, at 3:00 p.m. The

order further provided: “Said persons should bring their attorney and be prepared to

proceed. There will be no delay or continuance for counsel or otherwise.” The trial court

held the contempt hearing on September 3, 2019, at “approximately” 4:00 p.m.

Following the hearing, the court found Deters in contempt and sentenced him to 15 days

in jail. Deters filed this timely appeal.

Law and Analysis

{¶7} In one assignment of error, Deters challenges both the procedure and

merits of the contempt finding. Deters primarily argues that he was denied due

3 OHIO FIRST DISTRICT COURT OF APPEALS

process during the contempt hearing. First, Deters contends that he was denied the

right to counsel when the trial court conducted the hearing without obtaining a valid

waiver of counsel. Second, he claims that he was denied the right to a public trial

and the right to call witnesses when the court held the hearing after the courthouse’s

public hours. He also challenges the sufficiency of the evidence supporting the trial

court’s finding of contempt. Judge Schweikert defends the finding of contempt by

arguing that Deters’s conduct was in direct contempt of court, and thus, not subject

to due-process requirements.

I. Direct or Indirect Contempt

{¶8} Contempt may be either direct or indirect. In re Estate of Carrier, 1st

Dist. Hamilton No. C-030249, 2003-Ohio-6919, ¶ 13. The decisive determination is

whether the misconduct occurred in the presence of the court. Where the court lacks

personal knowledge of the conduct, and has to rely on information from witnesses to

establish contempt, the conduct is indirect contempt. State v. Stegall, 1st Dist.

Hamilton Nos. C-110767, C-120112 and C-120113, 2012-Ohio-3792, ¶ 39. The judge’s

reliance on witness testimony requires the trial court to afford the alleged contemnor

a certain level of due process. Id.; In re Chambers, 2019-Ohio-3596, 142 N.E.3d

1243, ¶ 32 (1st Dist.). “These rights include reasonable notice before the hearing, the

right to reasonable time to prepare a defense, the right to counsel, the right to

subpoena and call witnesses, the right to invoke the privilege against self-

incrimination (although the contemnor may be called as a witness), the right to an

impartial judge, and proof of guilt beyond a reasonable doubt.” In re Estate of

Carrier at ¶ 15.

{¶9} On the other hand, where the court has personal knowledge of the

conduct, the conduct is direct contempt. In re Thomas, 1st Dist. Hamilton No. C-

4 OHIO FIRST DISTRICT COURT OF APPEALS

030429, 2004-Ohio-373. Direct contempt may be found and punished summarily

pursuant to R.C. 2705.01. However, “[c]ourts must closely scrutinize proceedings in

which there is a departure from due-process guarantees out of concern for

potentially ‘grave abuses.’ ” Id. at ¶ 13. Accordingly, R.C. 2705.01 limits the court’s

power to summarily punish a contemnor in two ways: (1) the acts must be known to

the court personally such that no fact-finding determination is required; and (2) the

nature or quality of the acts must be such that the orderly and effective conduct of

the court’s business requires immediate suppression and punishment. Id.

{¶10} In this case, the trial court loosely followed the procedure for indirect

criminal contempt. The court provided Deters with written notice of the contempt

proceedings, acknowledged Deters’s right to retain counsel, allowed Deters the

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2020 Ohio 3518, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-deters-ohioctapp-2020.