In Ungar v. Sarafite, the U.S. Supreme Court ruled on a case involving the right to self-representation in court and contempt of court charges. The appellant, Ungar, was charged with criminal contempt after he repeatedly interrupted his own trial proceedings while representing himself in a New York state court. He argued that his Sixth Amendment rights were violated because he wasn't given an opportunity for mitigation or defense before being sentenced for contempt by Judge Sarafite. However, the Supreme Court upheld the conviction stating that there is no absolute constitutional right to behave in such disruptive manner during one's own trial even if they are acting as their own counsel; it also noted that due process does not require formal hearings prior to issuing direct criminal contempt sentences when misconduct occurs within view of presiding judge.

In the dissenting opinion for Ungar v. Sarafite, Justice Goldberg argued that the majority's decision failed to adequately protect a defendant's constitutional right to represent himself in court. He contended that while it was true that Mr. Ungar had been disruptive and disrespectful during his trial, this did not justify denying him his Sixth Amendment rights. The judge should have taken steps to control Mr. Ungar’s behavior rather than removing him from the courtroom entirely and appointing counsel against his wishes, which effectively silenced him for most of the proceedings. Furthermore, Justice Goldberg expressed concern about how this ruling could set a dangerous precedent by giving judges too much discretion over when they can deny defendants their right to self-representation based on perceived misconduct or incompetence.