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order is incorrect the remedy is to appeal, but, absent a stay, he must comply promptly with the order pending appeal. Persons who make private determinations of the law and refuse to obey an order generally risk criminal contempt even if the order is ultimately ruled incorrect. The orderly and expeditious administration of justice by the courts requires that an order issued by a court with jurisdiction over the subject matter and person must be obeyed ... until it is reversed by orderly and proper proceedings.... Such orders must be complied with promptly and completely, for the alternative would be to frustrate and disrupt the progress of the [court proceedings] with issues collateral to the central questions in [the case].’ (Citations and punctuation omitted.) Maness v. Meyers, 419 U.S. 449 , 458-459(II) (95 S.Ct. 584, 42 L.Ed.2d 574) (1975).” Hunstein and Benham dissent : “We have recognized that even a ‘slight conflict of interest [is] not permitted’ in death penalty cases. Sallie v. State, 269 Ga. 446, 448(2) (499 S.E.2d 897) (1998). That is true even where the conflict may be irrelevant to a death penalty defendant’s guilt or innocence. Fleming v. State, 246 Ga. 90, 93 (270 S.E.2d 185) (1980). … Moreover, even if a division of an attorney’s loyalties were ever feasible, it would not apply to the conflict of interest faced by counsel in this case because the conflict arose out of payment of counsel’s fees for the services to be rendered in their representation of Sanders. … A conflict over the fees counsel seeks to be paid for those services he may render his client would necessarily permeate every aspect of counsel’s representation of that client.” Lee v. State, 283 Ga.App. 369, 641 S.E.2d 615 (February 1, 2007). 1. Trial court’s finding of contempt against attorney was supported by the evidence. “Lee’s refusal to obey the trial judge’s order that he represent his client by participating in the trial was sufficient evidence from which a rational trier of fact could have found beyond a reasonable doubt that Lee was in contempt of court. See Jordan v. State, 166 Ga.App. 627, 629 (305 S.E.2d 165) (1983) (refusal of attorney to represent client supports order of contempt).” 2. Summary adjudication of contempt was proper where attorney, in trial court’s presence, refused to proceed with trial. “‘[D]uring trial, a trial judge has the power, when necessary to maintain order in the courtroom, 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.’ (Citation and punctuation omitted.) In re: Brant, 230 Ga.App. 283, 284(1) (496 S.E.2d 321) (1998). In the current case, the trial judge gave Lee ample opportunity to explain his refusal to obey the command that he defend his client at trial, and thereafter the judge committed no error in inflicting summary punishment for Lee’s direct contempt of court. See, e.g., In re: Omole, [December 5, 2002, below] (failing to respond to call of case for trial disrupts court proceedings and is contempt that may be summarily punished).” Dogan v. Georgia Department of Human Resources, 278 Ga.App. 905, 630 S.E.2d 140 (April 14, 2006). 1. Evidence supported trial court’s finding of contempt: Indirect “contempt may involve ‘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 [authority] to administer justice ,’” quoting In re: Spruell, 227 Ga.App. 324, 325(1) (489 S.E.2d 48) (1997). “Here, the evidence shows that Dogan – an attorney [representing himself in a child support proceeding] – represented to DHR that documents submitted in response to a request to produce were pay stubs. At the time he did so, Dogan understood that the information was being requested in connection with a hearing on his child support obligations. In other words, Dogan falsified documents, which he knew or had reason to suspect would be presented to the trial court. Clearly, this type of conduct interferes with the court’s authority to administer justice, such that the court was justified in holding Dogan in contempt.” 2. Trial court was not required to recuse itself in this situation. “A judge must recuse himself when a contemnor lies to the court in direct response to a question from the court [citing Schoolcraft (July 11, 2005), below ] or when the court’s actions evince a strong inference that the judge has become personally involved in the controversy. [See In re: Adams, 215 Ga.App. 372, 375(1) (450 S.E.2d 851) (1994).] In contrast, recusal is not required when the conduct occurs outside of the presence of the judge [cits.] or if there is no evidence that the judge is overly embroiled in the controversy. See In re: Longino, 254 Ga.App. 366, 370(5) (562 S.E.2d 761) (2002). Here, Dogan initially produced the falsified records to the attorney for DHR, so the conduct occurred outside the judge’s presence. [fn] Accordingly, the judge was not required to recuse himself on this basis. [Cit.] Moreover, there is no indication that the judge was overly invested in the controversy. Rather, the judge merely stated his concern regarding the falsified documents and informed Dogan that he was ‘inclined to find [Dogan] in criminal contempt.’” In re: Schoolcraft, 274 Ga.App. 271, 617 S.E.2d 241 (July 11, 2005). Trial court found counsel in contempt for giving court false information in a bond hearing. Held, finding of contempt reversed; trial judge should have recused himself. Because the judge participated in the dialogue (directly asked the question) that led to the allegedly contemptuous behavior, judge’s stake in the outcome created a conflict of interest. “‘Where the announcement of punishment is delayed, and where the contumacious conduct was directed toward the judge or where the judge reacted to the contumacious conduct in such manner as to become involved in the controversy, the judge may give
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