In Sword, the Michigan Supreme Court held that because the proceeding was a civil contempt which is essentially remedial or coercive and not criminal, no right to counsel exists.
Second, the trial court "exceeded its authority" by imposing a sentence "with no provision for allowing him to purge his contempt at any time". Compare Roblyer v Roblyer, 354 Mich. 226; 92 N.W.2d 330 (1958). Because the proceedings were civil, the Court of Appeals declined to extend the right to appointed counsel and jury trials, saying:
