State of Tennessee v. Christopher Anderson (In Re: David W. Camp)

Appellant, David W. Camp, appeals from the Madison County Circuit Court’s finding of criminal contempt for his failure to appear at a scheduled court appearance for Mr. Camp’s client, Christopher Anderson, the defendant in this case. The trial court summarily convicted Appellant under Tennessee Rule of Criminal Procedure 42(a), finding that Appellant was in direct contempt of court and that Appellant’s conduct was in the presence of the court. The trial court relied upon text messages received from Appellant explaining his whereabouts at the time of the scheduled court appearance. We conclude that the trial court’s finding that Appellant’s conduct was in the presence of the court is error, and therefore, we remand this case for a hearing in accordance with Tennessee Rule of Criminal Procedure 42(b).