Supreme Court of Georgia

Steel v. State

October 22, 2024320 Ga. 184

Summary

The Supreme Court of Georgia reversed Brian Steel’s criminal contempt judgment because the trial judge failed to recuse himself when he was a party to the controversy, violating Steel’s due‑process rights. The Court held that when punishment is delayed, a hearing must be conducted by a different judge. The Court did not reach Steel’s arguments concerning attorney‑client privilege or whether his conduct interfered with the court’s administration.