In an unreported case released on June 16, 2016 the Court of Special Appeals in Miller v. State, Nos. 0444 and 0836, Sept. Term, 2015 reversed a Circuit Court Judge’s determination that a spectator in the courtroom could be held summarily in contempt if the spectator’s cell phone rang during the course of a court proceeding.  The trial court summarily found the spectator guilty of contempt and ordered him to serve a five month sentence because the spectator’s cell phone went off during the courtroom proceeding.  The Court of Special Appeals held that before a person can be held in direct criminal attempt there must be evidence of a specific intent to disrupt the court proceeding.  In Miller there was no evidence of intent as the spectator told the Judge that he did not realize that his cell phone was on.