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760

Indirect Criminal Contempt—Institution of the Action

Judges and grand juries may initiate criminal contempt proceedings. NLRB v. A-Plus Roofing, Inc., 39 F.3d 1410 (9th Cir. 1994). The district court's power to initiate criminal prosecution against a party for contempt includes the authority to appoint a private attorney to prosecute the contempt. United States v. Vlahos, 33 F.3d 758 (7th Cir. 1994).

[cited in USAM 9-39.000]