Ezell v. Graham

The primary issue for our review is whether the Choctaw Circuit Court (“the trial court”) had before it sufficient evidence from which it could have determined beyond a reasonable doubt that Wendy Graham Ezell (“the mother”) committed criminal contempt by violating the visitation provisions of a 2002 judgment divorcing the mother from Christopher Graham (“the father”) as well as a pendente lite visitation order entered on August 25, 2011.

“ ‘Rule 70A(a)(2)(C)(ii) [, Ala. R. Civ. P.,] defines criminal contempt as “[wjillful disobedience or resistance of any person to a court’s lawful ... order,…