Burleigh Cty. Social Service Bd. v. Rath

Summary

The court affirmed the contempt order requiring Rath to pay child-support arrears. It held that Rath was not entitled to appointed counsel at the contempt hearing because incarceration was not automatically imposed and procedural safeguards protected his opportunity for counsel before any imprisonment. The court also rejected Rath’s challenges based on temporary custody, laches, standing, and federal garnishment limits. No separate opinions were filed.