Greg Spore v. State of Mississippi, 2017 Miss. LEXIS 91

On July 13, 2015, A.P.D. Greg Spore represented Jeremy Cowards at a probation-revocation/adjudication hearing before Judge Jeff Weill Sr.; Cowards was adjudicated guilty of burglary and sentenced to ten years with three suspended.
Before sentencing Spore argued mitigation several times; the judge repeatedly asked whether Spore had completed his argument and twice warned he would not hear further argument after pronouncing sentence.
After the judge announced sentence and reiterated that no further argument would be heard, Spore continued to speak, asserting he was "making his record" and referencing legal authority; the judge ordered him to sit and then found him in direct criminal contempt, imposing a $100 fine.
Spore appealed, arguing (1) he did not act contemptuously and (2) he did not violate professional or uniform-court rules; the State framed the issues as disobedience of a court order and willful disruption of court proceedings.
The Mississippi Supreme Court reviews criminal contempt de novo (ab initio) and requires proof beyond a reasonable doubt; the Court affirmed the contempt finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Spore’s conduct constituted direct criminal contempt by willfully disobeying the trial judge’s order and disrupting proceedings	Spore: he was zealously representing client and attempting to make a contemporaneous record; not attempting to disrupt or disrespect	State/Judge: Spore continued arguing after explicit admonitions and an assurance he was finished; his conduct disrupted and disrespected the court	Held: Affirmed — record shows beyond a reasonable doubt Spore willfully acted contemptuously and disrupted the court
Whether Spore violated professional/uniform-court rules (URCCC 3.02 / MRPC 3.5)	Spore: conduct was respectful, intended to preserve appellate record, not to disrupt	State/Judge: conduct violated duty to refrain from disruptive conduct and to manifest professional respect	Held: Affirmed — conduct violated the rules and supported contempt finding

In re Smith, 926 So.2d 878 (Miss. 2006) (defines direct criminal contempt and confirms ab initio review)
Purvis v. Purvis, 657 So.2d 794 (Miss. 1994) (contempt requires willful conduct bringing court into disrepute)
Brame v. State, 755 So.2d 1090 (Miss. 2000) (ab initio standard applied in contempt appeals)
Mississippi Bar v. Lumumba, 912 So.2d 871 (Miss. 2005) (attorney discipline for disruptive, disrespectful courtroom conduct)
In re Hoppock, 849 So.2d 1275 (Miss. 2003) (contempt power as tool to maintain order and efficiency)
Mingo v. State, 944 So.2d 18 (Miss. 2006) (refusal to proceed can constitute direct contempt and justify summary punishment)