Fiore v. Athineos

We reverse the circuit court’s order finding Malissa Fiore in direct criminal contempt in a combined paternity and dependency action.

On April 7, 2008, the court ordered the mother to execute her children’s passport applications in open court. She signed the passport applications under protest and executed an affidavit. The court said, “Defense counsel, thank you for your client’s compliance with this order.” At a hearing on April 14, without a written motion or notice to Fiore, the father told the court that the passport application required additional information and needed to be notarized.…