2006 New York Code - 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.