Luttrell v. Panozzo

Following a hearing on a rule to show cause, plaintiff Richard Luttrell was found in indirect civil contempt for violating an order restraining him from telephoning or coming within 100 feet of defendant Judy Panozzo and he was ordered to pay a fíne of $2,000. On appeal, he contends that the circuit court improperly applied the preponderance of evidence standard rather than that of proof beyond a reasonable doubt. We agree, and for the reasons that follow, we reverse the judgment and remand for further proceedings.

On August 2, 1990, plaintiff filed a complaint in the circuit court of Cook…