Al-Hakim v. State, ___ So. 3d ___, 36 Fla. L. Weekly D295 (Fla. 2d DCA 2/9/11)

The trial court held the defendant’s family member in direct criminal contempt of court for yelling and pointing his finger at the judge and creating a disturbance in the courtroom. The appellate court reversed because (1) the trial court did not ascertain whether the subject was entitled to appointed counsel because he was indigent, (2) the subject was not given an opportunity to respond before the judgment of contempt was imposed, and (3) the judgment “did not contain a recital of the facts upon which it was based.”