New York’s Appellate Division, 1st Department, has upheld an order of criminal contempt and a $1,000 fine for a prospective juror who during voir dire loudly referred to the defendant as a “scumbag,” approached the bench and had to be escorted from the courtroom.

On June 30, 2005, Stephen Caruso was called as a potential juror in a kidnapping case before Manhattan Supreme Court Justice William Wetzel.