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 and a written commitment order, and that a three‑day delay between a verbal contempt order and the signing of the commitment order is not a "short and reasonable" time, thus violating due process; the relator was ordered discharged. Justice CULVER, in a concurring opinion, disagreed with the majority’s view on the reasonableness of the three‑day delay and suggested statutory clarification.