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didn’t require that defendant be “notified that he violated a specific court order or statute, implying that there can be no criminal contempt without such a violation. This argument is a nonstarter. As OCGA § 15–1–4(a)(1) clearly contemplates, and as we have previously held, criminal contempt ‘involves some form of wilful disrespect toward the court; it may involve intentional disregard for or disobedience of an order or command of the court, or it may involve conduct which interferes with the court's ability to administer justice.’ In re Schoolcraft, 274 Ga.App. 271, 274(2), 617 S.E.2d 241 (2005) (punctuation omitted); see also In re Spruell, 227 Ga.App. 324, 325, 489 S.E.2d 48 (1997) (same). And here, at the evidentiary hearing, the State showed that prior to the close of evidence in his son's criminal trial, Moton directed loud, threatening comments toward several of the State's witnesses and, thus, engaged in behavior that ‘created a clear and present danger to orderly administration of justice.’ In re Jones, 198 Ga.App. 228, 231(6), 401 S.E.2d 278 (1990) (punctuation omitted); see also Wood v. Georgia, 370 U.S. 375, 384–85, 82 S.Ct. 1364, 8 L.Ed.2d 569 (1962); Garland v. State, 253 Ga. 789, 790(2), 325 S.E.2d 131 (1985).” Singleton v. State, 326 Ga.App. 609, 757 S.E.2d 211 (March 27, 2014). Armed robbery and related convictions affirmed; no mistrial required where trial court, in jury’s presence, held State’s witness in contempt for refusing to be sworn. “[U]nder the specific circumstances of this case there was no reversible error, even though the better practice would have been to remove the jury from the courtroom before holding a witness in contempt. See Roberts v. State, 208 Ga.App. 628(1), 431 S.E.2d 434 (1993) (holding that recommended practice is to remove jury from courtroom while trial court holds witness in contempt). Notably, Waters was called to the stand as a witness for the State. Therefore, the jury's knowledge that he was held in contempt for failing to testify was unlikely to give rise to any prejudicial inferences against Singleton. See Hendricks v. State, 283 Ga. 470, 473(3), 660 S.E.2d 365 (2008) (no prejudicial inference where trial court informed jury that State's witness refused to testify and was held in contempt). Moreover, the record shows that the State merely asked Waters to be sworn in, and never asked him any questions that suggested Singleton's guilt. [fn: Compare Lawrence v. State, 257 Ga. 423, 424–425(3), 360 S.E.2d 716 (1987) (finding reversible error where witness invoked right to remain silent and trial court thereafter in jury's presence permitted State to ask witness fourteen leading questions suggestive of defendant's guilt). ] Accordingly, under the circumstances of this case, Singleton has not shown that the trial court manifestly abused its discretion or that a mistrial was essential to the preservation of his right to a fair trial.” In re: Adams, 292 Ga. 617, 740 S.E.2d 134 (March 18, 2013). Evidence supported finding of criminal contempt against attorney who appeared unprepared for his client’s murder trial. “On … the day the parties would have made opening statements and the State would have begun calling witnesses, appellant did not have his entire case file with him; appellant could not advise the court as to when he or his investigators had talked to or had made attempts to talk to Landers who was considered to be a material witness for the State; and appellant admittedly had not obtained any certified copies of convictions despite the fact that a significant number of the State's witnesses, including Landers, had prior felony convictions and despite the fact that appellant had no knowledge of what order the State would call its witnesses.” In re: J.D., 316 Ga.App. 19, 728 S.E.2d 698 (May 18, 2012). Contempt finding affirmed. 1. Trial court wasn’t required “to designate the convictions for contempt as either criminal or civil. … ‘[T]he conditional or unconditional imposition of a fine or imprisonment indicates the purpose of an order. If the contemnor is imprisoned for a specified unconditional period (not to exceed 20 days under OCGA § 15–6–8(5) [See Reece v. Smith, 292 Ga.App. 875, 877(1) (665 S.E.2d 918) (2008) (explaining that a superior court is authorized to sentence a contemnor to 20 days in jail and to fine him up to $500 for each individual act of criminal contempt) (citing OCGA § 15–6–8(5)).]), the purpose is punishment and thus the contempt is criminal. If the contemnor is imprisoned only until he performs a specified act, the purpose is remedial and hence the contempt is civil.’ (Citations and punctuation omitted.) Thedieck, supra, 220 Ga.App. at 766(1); see also In re: Earle, 248 Ga.App. 355, 358(1)(b) (545 S.E.2d 405) (2001) (‘When the trial court orders incarceration for an indefinite period until the performance of a specified act, the contempt is civil.’) (citations and punctuation omitted).” Here, both findings of contempt carried 20 day jail sentences. Both were thus criminal, not civil, though the second “could be suspended upon her compliance with the juvenile court's protective order. The fact that Stallworth could suspend her sentence, however, did not render this second contempt civil. Significantly, her sentence was not ‘for an indefinite period’ until she in fact complied with the protective order or performed any other specified act. See Earle, supra, 248 Ga.App. at 358(1)(b). Rather, according to the juvenile court's order, even if Stallworth failed to comply with the protective order, she was nevertheless to be released after she served a total of 40 days (20 days for each contempt conviction) in prison. Accordingly, the convictions of contempt imposed upon Stallworth were both criminal, and the trial court did not commit reversible error by failing to specify the nature of the contempt.” 2. “‘In order to establish criminal contempt for violation of a court order, there must be proof beyond a reasonable doubt not only that the alleged contemnor violated a court order, but also that he did so wilfully. And to show wilfulness, there must be proof beyond a reasonable doubt that the alleged contemnor had the ability to comply with the court order: It is
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