of Court, supra, at 13. Last century's "contempt by publication/freedom of speech” American cases transformed the "tendency to prevent a fair trial” standard into an almost insurmountable elevated "clear and present danger to the administration of justice" standard. It was during this period when the "pending case" issue was relevant in America, as it is yet today in England. Any "pending case" language in the United States law of contempt is limited to these "contempt by publication” cases, which are fait accompli. See Myers v. State (1889), 46 Ohio St. 473, 491, 22 N.E. 43, 44-45 ("The offense consisted in the tendency of his acts to prevent a fair trial of the cause then pending in the court.")) Toledo Newspaper Co. v. United States (1917), 247 U.S. 402, 38 S.Ct. 560, 62 L.Ed. 1186 (<HOLDING>); Near v. Minnesota (1931), 283 U.S. 697, 51
holding that a commission is a body with special and limited power and it can only exercise the power expressly or impliedly granted to it and any reasonable doubt of existence of any power must be resolved against the exercise thereof holding that no sentence is imposed in the case of a sis holding no irreparable harm and thus no jurisdiction where no existing employeeemployer relationship holding that the act of 1831 conferred no power not already granted and imposed no limitations not already existing and a publication commenting on a pending case in federal court constitutes a contempt where it has a reasonable tendency to obstruct the administration of justice holding that an estate administration begins and the probate court obtains jurisdiction over the administration when the court issues letters of administration