Hicks v. Feiock (US 1988)

485 U.S. 624 (1988)
April 1988

As a general rule, if a fine paid to complainant will “purge” the penalty, then it is a civil contempt. However, if there are definite penalties, which cannot be purged through compliance, then the action is a criminal contempt. If both civil and criminal relief is imposed in the same action, then the criminal feature of the order is dominant and fixes its character a criminal for purposes of review and burdens of proof.

Hicks v. Feiock.pdf