Just as personal jurisdiction has been recast by the internet and online commerce, so too may new forms of communication expand the the concept of "contempt of court."
Very interesting article from Wired about a case currently being considered by the Seventh Circuit Court of Appeals. Litigant Kevin Trudeau, he of infomercial fame, apparently urged his fans to send emails to District Judge Robert Gettleman to try to get the judge to side with Trudeau in a pending civil lawsuit.
The resulting flood of messages actually caused the judge's Blackberry to freeze up, and Gettleman found Trudeau in contempt of court and sentenced him to jail. The Court of Appeals stayed the sentence, pending a decision on whether contempt of court can occur in a court's "virtual presence."