341044 - Wong v Thorington

The COA reversed the trial court’s order finding the respondent in criminal contempt due to the following issues: (1) the trial court allowed him to represent himself without first informing him of his right to an attorney or the public’s obligation to pay for his representation in the event of his indigence; (2) the trial court used conduct by the respondent outside of what was alleged in the show cause as a basis for finding him in contempt. The COA noted that Due Process required the Defendant to have adequate notice of the other violations before being called to defend himself from them.