State of Tennessee v. Paul Springer

CourtCourt of Criminal Appeals of Tennessee
DecidedJuly 15, 2025
DocketW2024-00849-CCA-R3-CD
StatusPublished

This text of State of Tennessee v. Paul Springer (State of Tennessee v. Paul Springer) is published on Counsel Stack Legal Research, covering Court of Criminal Appeals of Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Tennessee v. Paul Springer, (Tenn. Ct. App. 2025).

Opinion

07/15/2025 IN THE COURT OF CRIMINAL APPEALS OF TENNESSEE AT JACKSON Assigned on Briefs May 20, 2025

STATE OF TENNESSEE v. PAUL SPRINGER

Appeal from the Criminal Court for Shelby County No. 21 02433Roy B. Morgan, Jr., Senior Judge ___________________________________

No. W2024-00849-CCA-R3-CD ___________________________________

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.

Tenn. R. App. P. 3 Appeal as of Right; Appeal Dismissed

TIMOTHY L. EASTER, J., delivered the opinion of the court, in which ROBERT W. WEDEMEYER and MATTHEW J. WILSON, JJ., joined.

Tony N. Brayton, Assistant Public Defender – Appellate Division (on appeal); Glover Wright, Assistant Public Defender (at hearing on motion to dismiss), Memphis, Tennessee; Terrell Tooten (at trial), Cordova, Tennessee, and James Jones (at trial), Bartlett, Tennessee for the appellant, Paul Springer.

1 The record does not contain an indictment or other charging instrument, but the trial court announced Defendant’s charges in its opening instructions to the jury at Defendant’s trial. 2 Senior Judge Roy B. Morgan, Jr., presided over the motion hearing. Senior Judge Don R. Ash presided over Defendant’s October 2019 jury trial. Jonathan Skrmetti, Attorney General and Reporter; Elizabeth Evan, Assistant Attorney General; Steven J. Mulroy, District Attorney General; and Byron Winsett and Dennis Johnson, Assistant District Attorneys General, for the appellee, State of Tennessee.

OPINION

Factual and Procedural History

Defendant, a disbarred attorney,3 was charged with forgery and theft from a prior client. A jury trial began on October 2, 2019. Because the facts presented at trial are not relevant to the issue raised on appeal, we will not summarize them here. On the morning of the first day of trial, Defendant, who was released on bond, arrived forty minutes late, and he arrived fifteen minutes late after the lunch recess. The trial court gave the following warning:

I mean, when I say you don’t have to respect me. I don’t really care. I’m fine. But you’re going to respect this court. [Defendant] was 40 minutes late this morning to court with a jury trial. I don’t know how late you were until you walked in. I didn’t do anything but finish the instructions I was already giving so there’s no harm no foul. But this is warning one. Next time there will be a sanction and the next time there will be a bigger sanction. So I’m telling you don’t do this anymore. Deal?

On the second day of trial, the trial court ruled that evidence of the victim’s prior criminal history was inadmissible. The court stated, “[W]e’re not going to get into the prior convictions at all, period.”

On the third day of trial, Defendant was again late to court. The trial court asked defense counsel if he knew where Defendant was, and defense counsel stated, “I thought he was going to the restroom when I was coming off the elevator, Your Honor.” The trial court instructed the courtroom deputy to “walk out there and see if he comes out of the restroom.” The deputy returned and said Defendant was not in the restroom. When Defendant finally arrived, the trial court told him, “[Y]ou’re late.” Defendant explained, “I had a couple of surgeries that cause me to have a pretty severe dysplasia in my esophagus that causes me to go to the restroom.” The court responded, “Not buying it. Got anything else?” The court then found Defendant in contempt of court and sentenced him to ten days in jail. Defendant asserted, “I have witnesses that will tell you that I was in the restroom.”

3 See In re: Paul James Springer, BPR #021267, No. M2018-01730-SC-BAR-BP (Tenn. Oct. 2, 2018) (Order). -2- When the court told Defendant the deputy had already checked the restroom, Defendant said he was in a restroom on another floor of the courthouse. The trial court responded, “If you would have been here on time at 8:30 and said I need to go to the restroom, I would have been more than happy to let you do that.” The court continued, “So we’ll do that document and I’ll sign that when we get done today and they’ll take you into custody.”

Later that same day, Defendant testified on his own behalf. Defendant testified that the victim retained him to represent her in a criminal case and an unemployment matter. He said he charged her $10,000 for her criminal case. He testified it was “a pretty low fee for what I would normally charge” and explained, “it was a very high profile case.” Defendant then stated, “the State was seeking enhanced punishment because she was a career offender.” The prosecutor objected. The court stated, “I already ruled that you can’t mention her criminal record” and asked the prosecutor, “So you want a mistrial?” Defense counsel objected to a mistrial and requested a curative instruction. The trial court stated, “The question is [Defendant] just used the word ‘career offender’ after I told y’all we cannot consider the prior convictions. He just snuck it in. He cheated. You know it, I know it. . . . [H]e snuck it in so he could get in the prior convictions. That’s the decision he made.”

The trial court found Defendant in contempt again and ordered him to serve an additional ten days “for violating [the court’s] prior ruling when he clearly knows, he clearly as an attorney he clearly knows what you can say and not say and saying career offender is a back door way to put in the prior convictions. So I’m going to punish him for that.” The trial court declared a mistrial and stated, “To be honest with you, “I’ve never declared a mistrial maybe once in 25 years. Never done that. But I don’t know how to fix this after your client did this intentionally, intentionally, which is amazing. But that’s – so I don’t know how to unring that bell.”

Defense counsel requested “a hearing on the contempt.” The trial court responded, “Direct contempt. Just had one. You don’t get a hearing on direct contempt.” Defense counsel stated, “Your Honor, it would be our position that we would be allowed to get a hearing under Rule 42.” The court responded, “You don’t get one on direct contempt. . . . If you want to go up to the appellate court and see what they want to say – but it’s direct contempt directly in front of me. The punishment is immediate and there is no other hearing.”

On October 4, 2019, the court entered an order that states:

First Count of Contempt. The first day of trial, [Defendant] was 45 minutes late. On the same afternoon[,] [Defendant] was 15 minutes late. On this occasion, the jury was ready to proceed. The court gave [Defendant] a -3- verbal warning and said there would be a sanction on the next event. The third day of the trial, with the jury waiting, [Defendant] was 18 minutes late. The court find[s] him in contempt and sentences him to ten days in jail.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Tracy Rose Baker v. State of Tennessee
417 S.W.3d 428 (Tennessee Supreme Court, 2013)
State v. Boyd
51 S.W.3d 206 (Court of Criminal Appeals of Tennessee, 2000)
Hall v. Hall
772 S.W.2d 432 (Court of Appeals of Tennessee, 1989)
State v. Pendergrass
937 S.W.2d 834 (Tennessee Supreme Court, 1996)
Bailey v. Crum
183 S.W.3d 383 (Court of Appeals of Tennessee, 2005)
State v. Green
689 S.W.2d 189 (Court of Criminal Appeals of Tennessee, 1984)
State v. Rockwell
280 S.W.3d 212 (Court of Criminal Appeals of Tennessee, 2007)

Cite This Page — Counsel Stack

Bluebook (online)
State of Tennessee v. Paul Springer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-tennessee-v-paul-springer-tenncrimapp-2025.