Call the judge a "jackass." To be extra sure, describe a whole panel of appellate judges that way. If you want to really lock it down, throw in a comparison or two to Adolf Hitler.
This precedent was established on Monday when the Michigan Supreme Court reprimanded Geoffrey Fieger, best known for representing the now-imprisoned Jack Kevorkian, for appearing on Detroit-area radio shows and calling the state appellate judges "jackasses" and other names that were not reprinted. (They had pissed him off by overturning a $15 million judgment he had won.) Fieger had argued to the grievance board that he and other lawyers (and anybody else, I suppose) have a First Amendment right to criticize judges publicly. An intermediate body agreed with Fieger, but on appeal the state supreme court found 4-3 that the remarks were just "personal abuse," not protected speech.
Fieger's attorney said that Fieger would appeal to those jackasses at the U.S. Supreme Court.
Link: AP via FindLaw.com