Judge Must Rule in North Case

WASHINGTON — A federal appeals court today told a district judge he had erred in holding Lt. Col. Oliver L. North in contempt of court without first ruling on North’s challenge to the constitutionality of Lawrence E. Walsh’s appointment as independent counsel in the Iran- contra affair.

U.S. District Court Judge Aubrey Robinson had held North in contempt of court last month for refusing to comply with a subpoena from Walsh’s grand jury. The U.S. Circuit Court of Appeals, which had blocked North’s incarceration, ruled today that Robinson must reach a conclusion on the merits of North’s argument before citing him for contempt.