Special Counsel Patrick Fitzgerald is, like, totally totally pissed off.

Fitzgerald mocked Miller's claim that being denied cell phone and e-mail privileges would be adequate punishment: "Forced vacation at a comfortable home is not a compelling form of coercion."

Miller "could avoid even a minute of separation from her husband," he wrote in another section, "if she would do no more than just follow the law like every other citizen in America is required to do."

Even more troubling for Miller, Fitzgerald seemed to suggest that she could face criminal charges, in addition to her contempt citation.

"The court should advise Miller that if she persists in defying the court's order that she will be committing a crime," Fitzgerald wrote. "Miller and The New York Times appear to have confused Miller's ability to commit contempt with a legal right to do so....here...