Horn v. Shepherd, 294 Ga. 468

Parties divorced in 2009; multiple post-divorce contempt and modification motions followed, consolidated in Coweta County and assigned to Judge L. Jack Kirby.
Judge Kirby entered contempt and fee-related orders in 2011; Husband appealed and this Court (Horn I) reversed one purge condition but otherwise affirmed.
After remittitur, funds were deposited in the court registry; Husband moved to recuse Judge Kirby on December 18, 2012; Kirby forwarded the motion to the chief judge.
Chief judge assigned Judge Dennis T. Blackmon to hear only the recusal motion under the circuit’s random-assignment rule; Blackmon conducted a hearing and announced he would grant recusal but did not enter a written recusal order immediately.
While the recusal motion remained unresolved (no written findings), the GAL moved on previously filed contempt claims; Judge Blackmon held a contempt hearing March 27, 2013 and entered a contempt order against Husband.
The Supreme Court vacated the March 27 contempt order because Blackmon was authorized only to decide the recusal motion and lacked authority to decide unrelated contempt matters before written recusal and reassignment occurred; case remanded for reassignment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Judge Blackmon had authority to enter contempt order while assigned only to hear a recusal motion	Horn: Blackmon lacked authority; he was assigned solely to decide recusal and the assigned-judge (Kirby) retained exclusive control until recusal was formally granted and the case reassigned	Shepherd/GAL: Implicitly that Blackmon could resolve pending matters to avoid delay and address registry/disbursement issues	Court: Vacated contempt order — Blackmon exceeded limited authority; assignment to hear recusal did not authorize handling unrelated matters until written recusal and reassignment occurred

Horn v. Shepherd, 292 Ga. 14 (732 SE2d 427) (opinion on prior appeal addressing contempt and fees)
Mayor & Aldermen of the City of Savannah v. Batson-Cook Co., 291 Ga. 114 (728 SE2d 189) (describes elements required for a complete affidavit in recusal context)