Katie D. Stehle, Appellant v. Ernest W. Zimmerebner, Appellee

Summary

The court reversed and remanded an order imposing weekend incarceration for civil contempt based on Stehle's failure to make proper efforts toward paying a child-support arrearage. It held that incarceration for coercive civil contempt requires a determination that the contemnor has the ability to pay, and that the purge conditions must be definite, clear, and express. Chief Justice Brill concurred in the result on similar grounds, while Justice Danielson, joined by Special Justice Kelley, would have affirmed because the order was supported by the evidence and sufficiently definite.