State of New Mexico ex rel. Children, Youth and Families Department, Petitioner-Petitioner v. Janet Mercer-Smith…

Summary

The New Mexico Supreme Court reversed the district court's contempt order and vacated the $3.8 million award to the Mercer‑Smiths, holding that the contempt proceeding was not remedial and therefore could not support compensatory damages, attorney fees, or costs. The Court reasoned that civil contempt sanctions must be remedial, not punitive, and that no due‑process protections for criminal contempt were afforded.