In Bitter v. United States, 389 U.S. 15, 19 L. Ed. 2d 15, 88 S. Ct. 6 (1967), the Supreme Court held that the trial court's revocation of bail, made without a hearing or any explanation of reasons by the trial judge, had the "appearance and effect of punishment." Id. at 16. In Bitter, at the conclusion of the government's case, the defendant sought leave of court to go to his office to gather additional evidence for his defense. Although the defendant promptly appeared at every session of the trial, he was thirty-seven minutes late returning from the recess. The trial court revoked the defendant's bail for the remainder of the trial. See Bitter, 389 U.S. at 15-16. On appeal, the United States Supreme Court reversed the defendant's convictions because the revocation of his bail "was unjustified" and "it constituted an unwarranted burden upon defendant and his counsel in the conduct of the case." Id. at 16.