Anderson v. Anderson
To prove contempt, wilful design to avoid payments must be shown – arrearages alone are not sufficient.
Rotter v. Rotter
Court has broad powers, independent of contempt proceedings to enforce its judgment. The trial court can apply any remedy customarily available to courts of equity and appropriate to a particular case.
Schroeder v. Schroeder
(1) Divorce court can use contempt powers to enforce judgment. (2) Rights between parties are enforced by civil contempt. (3) Contemnor entitled to hearing with findings of fact of what he failed to do, that he had the ability to do it and what he must do to purge.
In re Marriage of Biel v. Biel
Criminal, rather than civil rules, apply to appeal for prosecution by FCC for non-payment of child support.
Paternity of J.L.V. v. M.W.G.
Courts have inherent power to hold in contempt those who disobey court orders – disobedience of a lawful court order constitutes contempt of court – in this case, for moving child without informing mother of child’s whereabouts.
In Re Marriage of Noack v. Noack
Remedial contempt can be imposed where defendant received notice of hearing, but did not appear at hearing.
State ex rel. N.A. v. G.S.
Punitive sanctions may not be applied in remedial contempt actions. Contemnor must have some ability to purge contempt. Order that defendant obtain and hold job is erroneous, since hiring defendant requires act of another, and therefore is not in defendant’s control.
State ex rel. V.J.H. v. C.A.B.
Contemnor entitled to hearing to seek to modify purge orders or to explain why he has not purged.
In re Marriage of Larsen
Requiring treatment for post-traumatic stress syndrome was appropriate purge order for civil contempt for repeated failure to pay child support.
In Support of B.L.T.
Contempt finding for no payments whatsoever was appropriate, but purge, not a stay, is the appropriate order.