SPINA, J.
Rule 43 of the Massachusetts Rules of Criminal Procedure, 378 Mass. 919 (1979), narrowly defines the circumstances in which a judge may summarily punish the offense of criminal contempt of court. Summary punishment may not be imposed, for instance, if the punishment exceeds three months' imprisonment or a fine of $500. Id. Where summary contempt is unavailable, the contempt must be referred for prosecution by complaint or indictment pursuant to Mass...
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