In Gompers v. Buck’s Stove and Range Company, 221 U.S. 418, 450 (1911), the U.S. Supreme Court observed that for civil contempt the punishment is remedial, and for the benefit of the complainant. A person imprisoned for civil contempt is committed to prison unless and until he performs the act required by the court’s order. “[He] carries the keys of his prison in his own pocket. He can end the sentence and discharge himself at any moment by doing what he had previously refused to do.”
Procedures for adjudication of civil contempt must comport with the due process standards mandated for all civil proceedings. In civil contempt proceedings, due process is met by the clear and convincing standard. Addington v. Texas, 441 U.S. 418 (1979).
