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

Summary

The court reversed and remanded a civil-contempt order incarcerating Stehle for failing to make sufficient efforts to reduce her child-support arrearage. It held that incarceration for coercive civil contempt requires a finding that the contemnor has the ability to comply, and that the purge conditions must be definite, clear, and express. Chief Justice Brill concurred in the result but provided additional analysis, while Justice Danielson, joined by Special Justice Kelley, would have affirmed.