N.Y. Judiciary Law § 755: When punishment may be summary

§ 755. When punishment may be summary. Where the offense is committed

in the immediate view and presence of the court, or of the judge or

referee, upon a trial or hearing, it may be punished summarily. For that

purpose, an order must be made by the court, judge, or referee, stating

the facts which constitute the offense and which bring the case within

the provisions of this section, and plainly and specifically prescribing

the punishment to be inflicted therefor. Such order is reviewable by a

proceeding under article seventy-eight of the civil practice law and

rules.