Isaac Lewis was held in contempt and fined after Savannah’s Recorder’s Court found that he operated illegal rooming houses in violation of a prior cease-and-desist order and municipal ordinances. He sought certiorari, arguing that the prior order came from an unrelated dismissed case and that he lacked a reasonable opportunity to correct the ordinance violations. The Court of Appeals of Georgia held that the recorder’s court could not use the prior order as the basis for contempt in the circumstances presented, but that Lewis had received adequate notice and an opportunity to contest the municipal-code charges during the three-day hearing. The court affirmed in part, reversed in part, vacated in part, and remanded for resentencing.