With no explanation, chose the best option from "A", "B", "C" or "D". is insufficient to establish a basis for direct criminal contempt arising from his non-appearance, and that he did nothing to obstruct the trial court’s ability to hold the hearing because, in fact, the hearing was held. The State responds by distinguishing between direct and indirect criminal contempt, noting that the former requires that the contemptuous act must occur in the immediate presence of the court, while the latter proceeding involves an act committed out of the presence of the court. It notes that the trial court’s order is based on caselaw that is binding in this District, holding that a failure to appear can be considered direct criminal contempt, even though physical presence before the trial judge is lacking. See Speer v. State, 742 So.2d 373, 373 (Fla. 1st DCA 1999) (<HOLDING>). Most districts hold similarly. See, e.g.,

A: holding that the failure to appear in court pursuant to a court order can constitute direct criminal contempt
B: holding evidence insufficient to show direct contempt and no basis for indirect contempt because of failure to meet procedural requirements
C: holding that mothers failure to appeal prior contempt order precluded her challenge to prior order in appeal from later order entered based upon prior contempt order
D: holding that 25 surcharge added to fees that otherwise would be compensatory was a criminal contempt sanction even though it was payable to the adverse party and not to the court reversing order for sanctions because court did not follow procedural requirements for criminal contempt
A.