State of Tennessee v. Paul Springer

Defendant, Paul Springer, was charged with two counts of forgery in an amount $60,000 or more but less than $250,000 and one count of theft in an amount $60,000 or more but less than $250,000.1 Defendant’s jury trial ended in a mistrial after Defendant “violat[ed] a court order” by referencing an alleged victim’s prior criminal record. During the trial, Defendant was twice held in contempt of court, once for arriving late to court and again for violating the court’s order. Nearly three years after judgments were entered against Defendant for two counts of direct contempt of court, Defendant filed a “Motion to Dismiss Contempt of Court,” which the trial court denied.2 Defendant appeals, arguing the evidence was insufficient to support a finding of contempt. Having reviewed the record and the briefs of the parties, we conclude that the trial court lacked jurisdiction to hear Defendant’s motion to dismiss. Therefore, we dismiss the appeal.