Compagnoni v. Compagnoni

COPE, Judge.

Luciano Compagnoni appeals an order of civil contempt for failure to pay child support. We reverse.

The order under review finds that there is a $4,068 child support arrearage. The order imposes 60 days’ incarceration, which may be purged by paying $4,068 forthwith. The order contains no other findings.

The former husband correctly contends that the order under review is deficient under Bowen v. Bowen, 471 So.2d 1274 (Fla.1985). In particular, the order omits two essential findings: (1) that the former husband willfully violated the child support order, and (2) that the former…