Section 3731 of title 18 has been construed to permit appeals by
United States in criminal contempt actions where a district court enters
tantamount to a dismissal of an indictment or an information. United
v. Sanders, 196 f.2d 895, 897 (10th Cir.), cert. denied, 344 U.S.
The conviction in a criminal contempt action is a final judgment
is immediately appealable. It is the settled rule that an order which fines
imprisons the contemnor in a civil contempt proceeding is reviewable only on
appeal from the final judgment of the main cause of action because a civil
contempt proceeding is in effect a continuation of the main proceeding.
Carbon Fuel Co. v. United Mine Workers, 517 F.2d 1348 (4th Cir.
However, an order of confinement under 28 U.S.C. § 1826 for refusing
just cause to testify or produce other information in response to a court
is immediately appealable.
[cited in USAM 9-39.000]