People v. Geiger 

Defendant was age 15 at time of fatal shootings of two men, and then provided statement to police about events that preceded the shootings; Defendant was not charged for any offense directly related to murders. State later prosecuted Defendant for his refusal to testify at retrial, 9 years later, of person charged with murders. Court initially sentened Defendant to 20 years, but supreme court reversed and on remand trial court resentenced him to 10 years. Defendant originally refused to testify based on his fifth amendment right, but 5 years later Defendant explained he refused to testify because he could not remember the events of day of murders. Ten-year sentence was not grossly disproportionate to nature of contemptuous act when considered in light of Defendant's previous criminal history. (O'BRIEN, concurring; LYTTON, dissenting.)