Supreme Court of Georgia

Steel v. State

October 22, 2024320 Ga. 184

Summary

The Supreme Court of Georgia reversed an attorney’s criminal contempt judgment because the trial judge delayed announcing the specific punishment, the alleged contempt was directed toward the judge, and the judge became personally involved in the underlying controversy. Those circumstances required the contempt hearing to be conducted by a different judge as a matter of due process. The court did not reach the attorney’s other challenges to the contempt finding.