The father of a victim of the Colorado cinema massacre yelled "rot in hell!" at the alleged gunman as a judge delayed officially charging him a day after ruling he stand trial.
Four or five people walked out of court after Judge William Sylvester postponed for two months a hearing to arraign James Holmes, the 25-year-old accused of shooting 12 moviegoers dead and injuring at least 58 others.
Following preliminary hearings this week it was ordered on Thursday that Holmes face trial over the massacre in Aurora, outside Denver, last July.
But the suspect's defence lawyers objected to the arraignment on Friday morning and the judge postponed the hearing until March 12.
After the announcement Steve Hernandez, father of victim Rebecca Wingo, shouted "Rot in hell, Holmes!" and guards immediately took him out of the room.