In Cheff v. Schnackenberg, 384 U.S. 373 (1966), the Court upheld a criminal contempt sentence of six months imposed without the benefit of a jury trial. Yet, the Court distinguished the conviction as involving a petty offense and concluded: "sentences exceeding six months for criminal contempt may not be imposed by federal courts absent a jury trial or waiver thereof." Id. at 380. The Court held that contempt was not an intrinsically serious offense and that punishment of six months in prison did not render an offense serious. The Court determined that an offense with a maximum penalty of six months' confinement was petty and a jury trial was not required. More relevant to this case, the Court, referencing Cheff, later stated: "Contempt did not 'of itself' warrant treatment as other than a petty offense; the six months' punishment imposed permitted dealing with the case as a prosecution for 'a petty offense, which under our decisions does not require a jury trial.'" Bloom v. Illinois, 391 U.S. 194 (1968) (quoting Cheff, 384 U.S. at 379-380).