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Under that exception, an allegation of ineffective assistance of counsel need not be raised on direct appeal and may be raised collaterally by filing a petition for a writ of habeas corpus after the time for a direct appeal has expired, if the petitioner can establish “harmful constitutional error.” Kinne, 161 N.H. at 45; see Bonser v. Courtney, 124 N.H. 796, 807-08 (1984); cf. Humphrey v. Cunningham, Warden, 133 N.H. 727, 732 (1990) (explaining that we will not consider an issue raised under th

Contempts are either direct or indirect.

To obtain relief, the petitioner must show harmful constitutional error.

To obtain relief, the petitioner must show harmful constitutional error.

The two classes of contempt, civil and criminal, are distinguishable by the character and purpose of the punishment imposed.

I The history leading up to the present dispute is lengthy, and many of the details can be found in Bonser v. Courtney, 124 N.H. 796 *420 (1984), Town of Nottingham v. Bonser, 131 N.H. 120 (1988), and Knox Leasing v. Turner, 132 N.H. 68 (1989).

Bonser v. Courtney, 124 N.H. 796, 808, 481 A.2d 524, 530-31 (1984) (trial judge may punish by means of contempt).

In Bonser v. Courtney, 124 N.H. 796, 807-08, 481 A.2d 524, 530 (1984), we described the nature of a petition for writ of habeas corpus: “We have long held that the standard of review in habeas corpus proceedings is whether the court pronouncing sentence acted beyond the scope of its jurisdiction.

In so arguing, the defendant alludes to the extended sense of “jurisdiction” that has been the vehicle for enlarging the scope of habeas corpus review to include consideration of constitutional defects affecting a commitment order, on the theory tfyat such error deprived the committing authority of jurisdiction it would otherwise have had.

More than seven years have passed since the events first giving rise to this litigation, which has required frequent and protracted appearances before the superior court, numerous orders by this court, proceedings in the United States District Court and the Court of Appeals for the First Circuit, and the prior appeal and opinion sub nom Bonser v. Courtney, 124 N.H. 796, 481 A.2d 524 (1984), from which we will summarize the facts through the spring of 1984.

Although this court has recognized that habeas corpus proceedings may be used to consider constitutional claims challenging jurisdiction after the time for appeal has expired, Bonser v. Courtney, 124 N.H. 796, 807-08, 481 A.2d 524, 530 (1984), we have previously held that procedural defaults may preclude later collateral review.

“The purpose of prosecution for criminal contempt is punitive, to vindicate the ‘authority and dignity’ of the trial court.” Bonser v. Courtney, 124 N.H. 796, 808, 481 A.2d 524, 531 (1984) (quoting Scarborough v. R.T.P.

Finally, he will be ordered to make payments only if the court *57 finds that he has the “ability to pay.” In such a situation, it can fairly be said that Sheedy, if incarcerated, will hold the keys to his own prison.