Stehle v. Zimmerebner

I agree with the majority’s decision to reverse and remand, but I write separately to provide a comprehensive analysis for my conclusion.

I. Coercive Civil Contempt

As early as the tenth century, the common law recognized the power of contempt.1 With the development of the chancery courts, the law of contempt split into criminal and civil contempt. See Omni Holding & Dev. Corp. v. 3D.S.A., Inc., 356 Ark. 440, 156 S.W.3d 228 (2004). Criminal contempt preserves the power of the court, vindicates its dignity, and punishes those who willfully disobey its orders, either directly or indirectly. Id.…