In re Marriage of Reynolds

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In 2010, Father and Mother divorced. Mother later filed a motion for rule to show cause (contempt motion) alleging that Father should be held in contempt for failing to comply with the dissolution degree and a subsequent modification order regarding production of certain income and tax documents. Ultimately, the trial court found Father in contempt for failing to provide Mother tax documentation from 2010 forward pursuant to the parties’ dissolution decree. The court of appeals reversed the trial court for abuse of discretion because the court did not strictly comply with the rule to show cause statute and failed to give Father a way to purge himself of contempt. The Supreme Court granted transfer, thereby vacating the court of appeals opinion, and affirmed, holding (1) the motion for the rule to show cause contained sufficient factual detail so as to excuse strict compliance and protect Father’s due process rights; (2) Father waived his objections to the evidentiary findings of the trial court, and the trial court’s factual determinations were supported by the evidence; and (3) the trial court was not required to give Father an opportunity to purge himself. View "In re Marriage of Reynolds" on Justia Law