Supreme Court upholds prison sentence for fraud on the court

In Brandt v. Gooding, the trial court held the plaintiff in contempt and sentenced him to six months in jail for creating a fraudulent document and presenting that document in deposition. The court upheld the finding of direct contempt. Direct contempt involves contemptuous conduct in the presence of the court, and the Supreme Court held that a deposition is a proceeding and is in the presence of the court even though a judge is not physically present.