Rake v. Spall

OPINION OF THE COURT

Marilyn L. O’Connor, J.

Respondent’s motion herein raises the important question of *365the nature of notice required in order for a default order of incarceration to result from a support order violation proceeding. The Support Magistrate found by default that respondent willfully violated the support order made for the benefit of E.S. He recommended the sanction of incarceration. The matter was duly transferred for a judicial confirmation of the willful violation finding and the imposition of a sanction. This court confirmed the findings and ordered respondent incarcerated. A…