Danielle Malmquist v. Shem Malmquist, 415 S.W.3d 826

Post-divorce injunction barred filing any action against the other party without written court permission.
Contempt petition was filed for alleged violations of that injunction; a prior contempt proceeding had occurred with related sanctions.
Before contempt hearing, Malmquist moved to recuse Judge Stokes based on a threat to the judge’s life; recusal motion was denied.
Judge Stokes found Malmquist in contempt on four counts and sentenced her to 10 days per count (concurrent); bond was allowed pending appeal.
This appeal challenges the denial of recusal and the sufficiency of the contempt evidence; the appellate court affirmed and remanded for final costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial judge abused his discretion by denying recusal.	Malmquist asserts the threat created bias and required recusal.	Stokes properly exercised discretion; threat was not credible and did not require recusal.	No abuse of discretion; recusal denial affirmed.
Whether the evidence supports contempt beyond a reasonable doubt.	Malmquist contends evidence did not prove willful violation of the injunction.	Malmquist violated the injunction on four counts; evidence sufficient.	Contempt convictions affirmed.

Bean v. Bailey, 280 S.W.3d 798 (Tenn. 2009) (disqualification based on appearance of bias; rule 10)
Lee Medical, Inc. v. Beecher, 312 S.W.3d 515 (Tenn. 2010) (abuse of discretion standard for abuse of discretion review)
Hawkins v. State, 586 S.W.2d 465 (Tenn. 1979) (definition of interest and disqualification standards)
Spann v. Abraham, 36 S.W.3d 452 (Tenn. Ct. App. 1999) (context of appellate review and standards of recusal)