Donald Trump stormed out of the courtroom in his New York fraud trial on Wednesday after earlier being fined $10,000 (£8,274).
The former US President was found to have breached a gagging order barring him from attacking court staff.
The fine came after he was called to the witness stand to explain why he said there was a person “who is very partisan” sitting alongside Judge Arthur Engoron.
Trump denied he was referring to a senior law clerk - a claim rejected by Judge Engoron in issuing the fine. "I find that the witness is not credible," the judge concluded.
Minutes later, the Republican frontrunner stormed out of the courtroom in an apparent fit of anger.
It came moments after one of his lawyers finished questioning fixer-turned-foe Michael Cohen in the case.
The judge had ordered all those participating in the trial not to make public comments about court staff after Trump made a social media post criticising a court clerk.
Earlier this month, Judge Engoron fined Trump $5,000 after finding he had not taken down a post disparaging the clerk.
In the New York civil fraud case, Trump faces claims he and his organisation falsely inflated the values of Trump's real estate properties and other assets in order to get tax benefits and better loan terms.
In a separate federal case, prosecutors also urged a judge to reinstate a gag order on Trump, citing recent social media posts about the former president's chief of staff.
US District Judge Tanya Chutkan, who is presiding over the federal case charging Trump with plotting to overturn the results of the 2020 election, last week temporarily paused her order barring Trump from making inflammatory comments about prosecutors, court staff and potential witnesses.
The ruling came as Trump's lawyers challenged the limited gag order in higher courts.
In a motion filed on Wednesday night, special counsel Jack Smith's team encouraged Judge Chutkan to put the restrictions back in place.
Prosecutors cited statements in social media and at a news conference over the last day by Trump about his former chief of staff, Mark Meadows, who he speculated may give evidence against him in exchange for immunity from prosecution.
One part of the post said: “Some people would make that deal, but they are weaklings and cowards, and so bad for the future our Failing Nation. I don't think that Mark Meadows is one of them but who really knows?"
