In this particular case, a person in the courtroom yawned loudly, to the extent that the judge felt that it was a deliberate attempt at being dis-respectful, and the person was sent off to jail for 6 months (link to article):
Drowsy spectators in one suburban Chicago courtroom might want to stifle their yawns from now on. Clifton Williams, 33, of Richton Park, is facing six months in jail for making what court documents call a yawn-like sound in Will county judge Daniel Rozak’s court last month. The yawn happened as Williams’ cousin, Jason Mayfield, was being sentenced for a drug charge.
Rozak found Williams in contempt of court and sentenced him to six months in jail. However, Rozak could free Williams after a status hearing, if Williams apologizes and the judge accepts.
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