The Ohio Supreme Court held that the standard for a criminal contempt conviction is the same as a regular criminal conviction: guilty beyond a reasonable doubt. Executive 200 had previously been enjoined from operating a pyramid scheme. They did not follow the previous injunction, and the Ohio Attorney General brought a second action to charge them with violating the earlier order. The Trial Court ruled that the standard to be applied was clear and convincing. The Supreme Court held that for any criminal conviction, including criminal contempt, the standard was beyond a reasonable doubt.

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