Defense attorney Brian Steel was summarily held in contempt after refusing to reveal how he learned of an ex parte meeting during a high-profile criminal trial. The appeal asked whether the same trial judge could adjudicate and punish the contempt after becoming personally embroiled in the dispute and delaying the punishment rather than imposing it immediately to preserve courtroom order. The Supreme Court of Georgia reversed. It held that due process required the contempt matter to be heard by another judge because the circumstances showed sufficient personal embroilment and the delayed punishment removed the narrow justification for same-judge summary contempt. The court did not need to resolve the underlying privilege fight to decide the case; the contempt order failed because the procedure itself did not satisfy the neutrality required when judge and advocate become part of the controversy.