September 2014 | 485 U.S. 624 (1988)
Hicks v. Feiock (US 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.
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