Illinois lawyer Alison Motta “continually rolled her eyes, mumbled under her breath, and made audible comments” during a criminal trial in which she was acting for the defence, according to a disciplinary report.

Ms Motta’s behaviour culminated with her “rolling her eyes and saying ‘fucking bullshit’ after the judge overruled one of her objections” — which was caught on her microphone and heard by the court.

She admitted making the remark but told a disciplinary investigation that she said it to her co-counsel and intern under her breath and did not expect anyone else to hear it.

A hearing board recommended that Ms Motta, a partner at US law firm Motta & Motta, receive a fully-suspended 90-day suspension, the ABA Journal reports.