In re Adams, 292 Ga. 617

Appellant Herbert Adams, attorney, was found in wilful contempt for being unprepared at Michael Blaine’s murder trial in DeKalb County Superior Court.
Judge Mark Anthony Scott continued the trial and held Adams in contempt after questioning him about preparation and the State’s witnesses.
Adams had sought continuances; one was denied, another was taken under advisement as he was told to work with the prosecutor on witness interviews.
Before trial, Adams failed to produce certified convictions or fully explain his interview efforts with key witnesses, including Landers.
The State’s witness contact information had been withheld due to a prior murder of a key witness, but the prosecutor offered to facilitate interviews, which Adams did not adequately pursue.
The contempt judgment was entered on October 3, 2011, and Adams appealed, alleging recusal and sufficiency issues among others.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was recusal sua sponte required and preserved?	Adams argues Scott should have recused himself.	State asserts no timely motion for recusal was filed, waiving the issue.	Recusal waived; no timely motion filed.
Was the evidence sufficient to support contempt for being unprepared?	Adams contends insufficient preparation evidence exists.	State asserts record shows Adams failed to be prepared with case file, witness histories, and orders.	Evidence sufficient; rational trier could find contempt beyond reasonable doubt.
Did Adams preserve an ineffective assistance claim for not seeking recusal?	Adams asserts ineffective assistance for not filing a motion to recuse.	No timely new-trial motion; appellate filing lacks contempt counsel signature; issue waived.	Issue waived; not preserved for review.

In re Irvin, 254 Ga. 251 (1985) (standard for criminal contempt sufficiency)
In re Fitts, 259 Ga. App. 462 (2003) (sufficiency of evidence for contempt)
In re Longino, 254 Ga. App. 366 (2002) (sufficiency of evidence standard)
Jackson v. Virginia, 443 U.S. 307 (1979) (reasonable-doubt standard for criminal convictions)
In re Earle, 248 Ga. App. 355 (2001) (contempt for unpreparedness sufficiency)
Stegall v. State, 308 Ga. App. 666 (2011) (waiver of ineffective-assistance claims on appeal)