Bloom v. Illinois, 391 U.S. 194, 20 L. Ed. 2d 522, 88 S. Ct. 1477 (1968), presented the question whether a state court could sentence a criminal contemnor to two years imprisonment without a jury trial. The Bloom court began by observing that the Court had "consistently upheld the constitutional power of the state and federal courts to punish any criminal contempt without a jury trial." Id. at 195-96. The Court acknowledged the holding of Cheff v. Schnackenberg that contempt was not an intrinsically serious offense and that punishment of six months in prison did not render an offense serious. Justice White, writing for the Bloom majority, then explained: Our deliberations have convinced us, however, that serious contempts are so nearly like other serious crimes that they are subject to the jury trial provisions of the Constitution, now binding on the States, and that the traditional rule is constitutionally infirm insofar as it permits other than petty contempts to be tried without honoring a demand for a jury trial. Given that criminal contempt is a crime in every fundamental respect, the question is whether it is a crime to which the jury trial provisions of the Constitution apply. We hold that it is, primarily because in terms of those considerations which make the right to jury trial fundamental in criminal cases, there is no substantial difference between serious contempts and other serious crimes. Indeed, in contempt cases an even more compelling argument can be made for providing a right to jury trial as a protection against the arbitrary exercise of official power. (Bloom at 198-202.)