Calling a judge a vulgar name may be disrespectful, but it is not necessarily criminal contempt, the Pennsylvania Supreme Court has ruled, overturning the conviction of a man who served 30 days in jail for an outburst in a Philadelphia courtroom.

The court unanimously found that Basile Outlaw’s remark, though crude, did not significantly disrupt proceedings or obstruct the administration of justice. “Mere affront to the trial judge is not enough,” Justice David Wecht wrote in the court’s [opinion](https://cases.justia.com/pennsylvania/supreme-court/2026-48-eap-2024.pdf).

Outlaw was attending a June 2022 hearing before Philadelphia Common Pleas Judge Roxanne E. Covington to support a friend facing criminal charges. After Covington denied the friend’s motion to suppress, Outlaw stood and said “the judge is a cocksucker,” loudly enough for her to hear.

When Covington asked, “What did you say?” Outlaw replied, “Never mind. I’m leaving,” and walked out. A deputy sheriff and a court employee searched the building for him, but Outlaw returned on his own to apologize. He was taken into custody for direct criminal contempt, sentenced to 30 days and served the sentence.

On appeal, the Philadelphia District Attorney’s Office agreed with Outlaw that the evidence was insufficient to sustain the conviction. The Superior Court nevertheless upheld it. The Supreme Court then invited the Pennsylvania Attorney General’s Office to defend the conviction, and the office accepted.

Under Pennsylvania law, direct criminal contempt requires misconduct in the court’s presence, intent to obstruct proceedings and an actual obstruction of the administration of justice. The Supreme Court said that obstruction must amount to a significant disruption, not merely offensive behavior or a brief interruption.

In Outlaw’s case, the hearing paused only long enough for Covington to ask what he had said. The court compared that interruption to the transient delay at issue in *Williams v. Williams*, a 1998 case in which a litigant called a judge a “fucking asshole.” The justices declined to rank the insults by offensiveness, finding no reason to treat one as more obstructive than the other.

The court also cautioned judges against equating personal offense with interference in the administration of justice, describing trial judges as people expected to operate in a “hardy environment.”

Other jurisdictions have reached different outcomes in courtroom profanity cases, including cases involving lawyers, whose professional responsibilities differ from those of spectators.

Aaron Marcus of the Defender Association of Philadelphia, who represented Outlaw, told [The Philadelphia Inquirer](https://www.inquirer.com/news/philadelphia/philadelphia-curses-criminal-contempt-judge-supreme-court-20261104.html) that being offended should not justify a lasting criminal conviction. The ruling removes Outlaw’s conviction, but it cannot restore the month he spent in jail.