Ex Parte Oscar Calvillo Amaya A/k/a Oscar Calvillo

Summary

The Texas Supreme Court held that a trial court may not imprison a person for civil constructive contempt without a written judgment of contempt and a written commitment order, and that a three‑day delay in signing such orders exceeds the permissible "short and reasonable" time, thus ordering the relator discharged; Justice Culer filed a concurring opinion disagreeing with the majority's view on the reasonableness of the delay and urging clarification of the rule.