The trial court held an attorney in contempt through a summary proceeding and entered a contempt order. The Georgia Court of Appeals vacated the order and remanded. The court held that the procedure violated due process because the record did not show adequate notice and an opportunity to be heard before the contempt finding. The court also could not properly review the sufficiency of the evidence because important materials discussed at the hearing were not admitted or included in the record, and the trial court’s order did not identify the commands allegedly violated with sufficient clarity. The court left recusal and other issues for the trial court to address in the first instance.