The appellant appealed a one-year sentence for civil contempt imposed by the trial judge.
The appellant argued the sentence was excessive, that the judge was inflamed by the appellant's non-compliance with asset freezing and disclosure orders, and that the sentence was purely punitive rather than coercive.
The appellant also contended the sentence was out of line with other civil contempt cases.
The Court of Appeal dismissed the appeal, finding the sentence appropriate given the appellant's multiple opportunities to purge contempt, attempts to deceive the court, the brazen and deliberate nature of the contempt, the underlying $7 million civil fraud, and the lack of asset recovery despite the judge's delay in imposing sentence.