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requirement that the court must render into a writing spread upon the record of the court any direction to an officer as a prerequisite to compelling obedience to its commands.’ In re: Smith, [211 Ga.App. 493, 495(1), 439 S.E.2d 725 (1993)]. See In re: Irvin, 171 Ga.App. 794, 796(1) (321 S.E.2d 119) (1984), reversed in part on other grounds by 254 Ga. 251 (328 S.E.2d 215) (1985). Accordingly, Beckstrom was properly found in contempt under OCGA § 15-1-4(a)(2) for his failure to comply with the trial judge's directive that he appear for trial, communicated to him in the two faxed letters and his telephone conversation with the judge. See In re: Smith, 211 Ga.App. at 495-496(1); In re: Irvin, 171 Ga.App. at 796(1). See also In re: Booker, 195 Ga.App. 561, 563(1) (394 S.E.2d 791) (1990) (noting that defense counsel committed direct contempt by failing to comply with the trial judge's directive, communicated to him over the telephone, to appear for trial at a certain time).” In re: Hadaway, 290 Ga.App. 453, 659 S.E.2d 863 (March 24, 2008). Trial court denied adoption petition and ordered that child be returned to biological mother. Petitioner did return the child, but mother then gave child back to petitioner, who filed a new adoption petition in a different county. Original court then holds petitioner and petitioner’s attorney in contempt for “disobeying and resisting” the court’s order. Held, f inding of contempt reversed. “The order was directed toward the actions required of the natural mother. It did not address [petitioner] Hadaway’s or [attorney] Johnson’s obligations. If anyone violated the order, it was the natural mother. Therefore, neither Hadaway nor Johnson should have been found in contempt of that order. American Express Company v. Baker, 192 Ga.App. 21, 23(2) ( 383 S.E.2d 576) (1989) (‘A person cannot be found in contempt of a court order or writ which was not directed to him.’).” Further, “[t]he fact that they filed another petition to change custody, rather than file an appeal, does not mean that they willfully violated the order.” In re: Hatfield, 290 Ga.App. 134, 658 S.E.2d 871 (March 7, 2008). Trial court erred in finding attorney in contempt with opportunity to be heard, and after becoming involved in the controversy. 1. Attorney’s appeal of contempt finding didn’t become moot by paying the fine; “a contempt of court conviction against an attorney ‘would be especially damaging if [he] were ever again accused of being in contempt of court. Conviction for contempt of court could also have serious adverse career consequences for [the attorney]. His conviction could provide a basis for disciplinary action by a bar association. Opportunities for appointment to the bench or to other high office might be foreclosed as a result of this blot upon his record. The conviction might damage [his] reputation in the legal community, and this in turn might affect his ability to attract clients and to represent them effectively, especially in open court,’” quoting United States v. Schrimsher , 493 F.2d 842 (5th Cir., 1974). Accord, Morris v. State , 295 Ga.App. 579, 672 S.E.2d 531 (January 15, 2009) (lawyer’s appeal of contempt finding not moot although no sanction imposed). 2. Trial court erred in failing to give attorney notice that it was considering a finding of contempt. “When necessary to maintain order in the courtroom, the judge has the power to declare conduct committed in his presence and observed by him to be contemptuous and, after affording the contemnor an opportunity to speak in his or her own behalf, to announce punishment summarily and without further notice or hearing and then to postpone the carrying out of the punishment until after trial. [Cit.] That is not what happened here, because the court did not declare Hatfield’s conduct contemptuous or announce punishment until the end of the proceeding,” without notifying attorney that it was considering a citation of contempt. 3. “In Maples [ v. Seeliger, 165 Ga.App. 201, 202(1) (299 S.E.2d 906) (1983)] , we recognized that it is ‘ not every attack on a judge that disqualifies him from sitting’ and that ‘[a] lawyer’s challenge, though disruptive, recalcitrant and disagreeable, still may not be that insulting attack upon the integrity of the judge carrying such potential for bias as to require disqualification. ’” “Hatfield’s conduct certainly was not an insulting attack upon the integrity of the judge carrying such potential for bias as to require disqualification; nor did the judge's initial response require recusal. But when Hatfield was brought back into court at the end of the proceeding and the judge found him in contempt based at least in part on prior conduct that is not a matter of record in this proceeding, the judge thereby became involved in the controversy. … Moreover, although the judge informed Hatfield of the conduct found to be contemptuous, he refused to give Hatfield an opportunity to be heard. Even though that omission alone does not necessarily require recusal of the judge, [See Maples, supra] it does necessitate a reversal of his contempt conviction and a remand for another contempt hearing. In this case, the hearing must be before another judge, not because Hatfield was denied an opportunity to be heard, but because the judge who found Hatfield in contempt became involved in the controversy.” “Contemptuous” behavior here involved announcing “not ready” for trial. In re: Jefferson, 283 Ga. 216, 657 S.E.2d 830 (February 25, 2008). Announces new test for contempt “in the context of courtroom advocacy,” replacing the “clear and present danger to the orderly administration of justice” test from Garland v. State , 253 Ga. 789, 790(2), 325 S.E.2d 131 (1985) with a “more complete” test considering both act and intent. As to the act, adopts an “imminent threat” of disruption standard; as to intent, adopts an objective/subjective standard: “contempt may be found only where the attorney ‘knows or reasonably should be aware in view of all the circumstances,
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