The judge overseeing Donald J. Trump’s criminal trial in Manhattan held the former president in contempt for a second time in two weeks, fining him $1,000 on Monday for breaking a gag order that bars him from attacking jurors, and warning that he could jail him for “a direct attack on the rule of law.”
Addressing Mr. Trump personally, the judge, Justice Juan M. Merchan, said that financial penalties had failed to serve as a sufficient deterrent and time behind bars could be next.
“The last thing I want to do is put you in jail,” Justice Merchan said, adding quickly, “But at the end of the day I have a job to do.”
As the judge delivered his remarkable admonition, Mr. Trump stared straight at him, blinking but not reacting, and when the judge concluded, the former president shook his head.
Prosecutors from the Manhattan district attorney’s office, which brought the case against Mr. Trump accusing him of falsifying records to cover up a sex scandal, had argued that Mr. Trump had committed four violations of the order, which also prevents attacks on prosecutors, witnesses and others. But Justice Merchan concluded that only one of those instances amounted to a violation.
Still, the ruling represented the judge’s latest effort to rein in Mr. Trump’s heated rhetoric. It came less than a week after Justice Merchan issued a separate decision fining Mr. Trump $9,000 for nine earlier violations. In that first ruling, the judge said that he lacked the authority to issue larger fines against the billionaire former president and warned him that continued disobedience could land him in jail.
The two contempt findings were the latest reminder of the great lengths to which judges have gone to keep Mr. Trump from lashing out at participants in the wide array of legal matters in which he is embroiled.
Last year, another judge in Manhattan twice found Mr. Trump in contempt during a civil fraud trial and imposed tens of thousands of dollars in fines. The former president is also under a gag order in a federal case in Washington in which he has been charged with plotting to overturn the 2020 election, but he has not yet been accused of violating that one.
Mr. Trump has bridled in various ways at the constraints of Justice Merchan’s order, which was first put in place in March and then expanded several days later.
On Thursday, for instance, one of his lawyers, Susan Necheles, asked Justice Merchan to evaluate a stack of articles that Mr. Trump had wanted to post online about the case.
Ms. Necheles expressed concern that the articles might violate the gag order because they mention the names of witnesses, but Justice Merchan refused to rule in advance about whether Mr. Trump could post them, cautioning Ms. Necheles, “When in doubt, steer clear.”
That same afternoon, when court let out for the day, Mr. Trump falsely told reporters that the gag order would prevent him from testifying in his own defense at the trial. On Friday morning, Justice Merchan took a moment to publicly correct the former president, instructing him that order “does not prevent you from testifying in any way.”