In Bloom v. Illinois (1967), the U.S. Supreme Court ruled that a defendant has the right to trial by jury in serious criminal contempt cases, overturning an Illinois man's conviction for contempt of court because he was denied a jury trial. The case involved Marvin Bloom who had been sentenced to 24 months imprisonment for willfully failing to pay alimony and child support as ordered by a divorce decree, which constituted criminal contempt of court under state law. In its decision, the Supreme Court held that despite being labeled "contempt," such offenses were essentially criminal and carried severe penalties; therefore they fell within the purview of Sixth Amendment protections guaranteeing defendants' rights in "all criminal prosecutions." This ruling significantly expanded defendants' rights during trials for indirect or constructive contempts committed outside courts' immediate presence.

In the dissenting opinion for Bloom v. Illinois, Justice Harlan argued that the majority's decision to require jury trials in all criminal contempt cases was an unnecessary and impractical extension of constitutional protections. He contended that not all instances of contempt were serious enough to warrant a jury trial, and suggested that this requirement could potentially disrupt court proceedings by causing delays or deterring judges from maintaining order in their courts. Furthermore, he disagreed with the majority's interpretation of "serious" crimes as those punishable by more than six months imprisonment, arguing instead for a case-by-case determination based on factors such as potential punishment severity and societal stigma attached to conviction. Finally, Justice Harlan expressed concern about how this ruling might affect other areas of law where similar penalties are imposed without juries (e.g., administrative law), thereby creating inconsistencies within legal system.