Jannis Collins was present in a superior-court proceeding as a potential witness when she spoke from the gallery despite instructions that she remain silent and sequestered. The State later initiated a criminal-contempt proceeding against her. Collins moved to dismiss, arguing that the State, rather than the trial judge, had no authority to institute the contempt case. The Court of Appeals of Georgia reversed the denial of her motion. It held that the proper procedure for criminal contempt arising from courtroom conduct is for the trial judge to institute the proceeding, while the State may pursue an ordinary criminal indictment if the conduct constitutes another offense. Because the State had been a stranger to the underlying civil action and had initiated the contempt proceeding itself, the motion to dismiss should have been granted. The judgment was reversed, and the appellate court did not decide whether Collins’s conduct otherwise warranted punishment.