How many presidents do you know that engaged in insurrection? Gag orders
See, for example, State v Plunkett, 934 P2d 113, 116 (Kan 1997) (upholding termi-
nation of defendants self-representation after he maintained a surly, disrespectful atti- tude throughout the proceeding, became belligerent and used profanity during argument on motions, refused to stand when addressing the court, and stopped answering the judge's questions); People v Davis, 851 P2d 239, 243-44 (Colo App 1993) (upholding exclu- sion of defendant from courtroom after he spat in the prosecutor's face, fought with deputy sheriffs, and physically attacked and shouted obscenities at a prosecution witness).
2 See, for example, Stewart v Corbin, 850 F2d 492, 494-96 (9th Cir 1988) (defendant threatened the trial judge, used abusive language, and intimidated a witness with his conduct).
' Illinoisv Allen, 397 US 337, 343-44 (1970) (holding that constitutionally permissi- ble remedies include binding and gagging the defendant, citing him for contempt, or re- moving him from the courtroom). See also Tanksley v State, 946 P2d 148, 150-51 (Nev 1997) (finding defendant in contempt for talking back and behaving disrespectfully); Scurr,647 F2d at 855 (upholding court order that defendant wear handcuffs and a body belt inside a coat after he assaulted a jailer); Stewart, 20 F3d at 915 (affirming lower court's decision to place defendant in leg irons during trial); Stewart, 850 F2d at 499-500 (affirming decision to gag defendant for repeatedly disobeying court orders and intimi- dating a witness). Source University of Chicago unbound