When a fine or commitment is imposed for the purpose of vindicating the authority of the court, the contempt is criminal rather than civil. Purpura v. Purpura, 115 N.M. 80, 82, 847 P.2d 314, 316 (Ct.App. 1993). "Conduct violating a court order in the court's presence constitutes direct criminal contempt."

{27} A person who commits disruptive or defiant conduct in the midst of an ongoing court proceeding within the personal perception of the judge has committed an act of direct criminal contempt and may be punished summarily without further evidentiary proceedings. See, e.g., Purpura v. Purpura ( In re Cherryhomes), 115 N.M. 80, 81-82, 85, 847 P.2d 314, 315-16, 319 (Ct. App. 1993) (upholding a finding of contempt where an attorney disobeyed the judge's direct orders, attempted to leave the court room before the hearing had finished, and pushed the sheriff's deputy who was attempting to restrain him). If feasible, even in summary proceedings for an act of direct contempt occurring in open court, an "adequate opportunity to defend or explain one's conduct is a minimum requirement before imposition of punishment."

We note that Rule 5-106(H) does not require the recusal of a district court judge or the removal of a prosecutor based on the judge or prosecutor's prior work as a prosecutor, whether such prior prosecution involved the present defendant or not. See id.; see also State v. Trujillo, 2009-NMCA-128, ¶¶ 9-12, 147 N.M. 334, 222 P.3d 1040 (finding no error in a judge's denial of a motion to recuse despite the judge's purported prior knowledge of the defendant and stating that, "[i]n order to require recusal, bias must be of a personal nature against the party seeking recusal" (emphasis added) (internal quotation marks and citation omitted); Purpura v. Purpura, 1993-NMCA-001, ¶ 16, 115 N.M. 80, 847 P.2d 314 ("[A] judge shall recuse himself or herself in any proceeding in which the judge has a personal bias or prejudice concerning a party." (emphasis added) (internal quotation marks and citations omitted)); State v. Hernandez, 1993-NMSC-007, ¶ 44, 115 N.M. 6, 846 P.2d 312 ("Personal bias cannot be inferred from an adverse ruling[.]"

“The district court has inherent power to sanction for contempt.” Purpura v. Purpura, 1993–NMCA–001, ¶ 6, 115 N.M. 80, 847 P.2d 314; seeN.M. Const. art. VI, § 13. The contempt power is necessary to allow courts to “to regulate their docket, promote judicial efficiency, and deter frivolous filings,” and “[i]t has long been recognized that a court must be able to command the obedience of litigants and their attorneys if it is to perform its judicial functions.”

"The district court has inherent power to sanction for contempt." Purpura v. Purpura, 1993-NMCA-001, ¶ 6, 115 N.M. 80, 847 P.2d 314; see N.M. Const. art. VI, § 13. The contempt power is necessary to allow courts "to regulate their docket, promote judicial efficiency, and deter frivolous filings," and "[i]t has long been recognized that a court must be able to command the obedience of litigants and their attorneys if it is to perform its judicial functions."

“The district court has inherent power to sanction for contempt.” Purpura v. Purpura, 1993–NMCA–001, ¶ 6, 115 N.M. 80, 847 P.2d 314 ; see N.M. Const. art. VI, § 13. The contempt power is necessary to allow courts to “to regulate their docket, promote judicial efficiency, and deter frivolous filings,” and “[i]t has long been recognized that a court must be able to command the obedience of litigants and their attorneys if it is to perform its judicial functions.”

Reid v. N.M. Bd. of Exam'rs of Optometry, 1979-NMSC-005, ¶ 6, 92 N.M. 414, 589 P.2d 198. "[A] fair and impartial tribunal requires that the trier of fact be disinterested and free from any form of bias or predisposition regarding the outcome of the case." Purpura v. Purpura, 1993-NMCA-001, ¶ 14, 115 N.M. 80, 847 P.2d 314. The decision to recuse lies in the discretion of the district court judge and is only required when that judge "has become so embroiled in the controversy that he or she cannot fairly and objectively hear the case."

The contempt power derives from common law and is an inherent power of the court. See State v. Clark, 56 N.M. 123, 125, 241 P.2d 328, 329 (1952); Purpura v. Purpura, 115 N.M. 80, 82, 847 P.2d 314, 316 (Ct.App. 1993). A court may impose a criminal contempt sanction for violation of a court order.

The State counters, and we agree, that the original order for sanctions, which was in part a contempt order and in part similar to a contempt order, and the order for suspension were both final and appealable when entered. See Purpura v. Purpura, 115 N.M. 80, 81, 847 P.2d 314, 315 (Ct.App. 1993) (addressing an appeal from an order holding attorney in direct criminal contempt entered during a civil case). Accordingly, the issues raised in this case were not unreviewable on appeal from the final orders entered.

Whether a judge should recuse himself or herself if his or her impartiality might reasonably be questioned places disqualification within the conscience and discretion of the judge. See Purpura v. Purpura, 115 N.M. 80, 84, 847 P.2d 314, 318 (Ct.App. 1993). Therefore, on appeal, we review Judge Cornish's decision not to recuse himself under an abuse-of-discretion standard.