In re the Marriage of Yowman

In this domestic relations case, mother appeals an order holding her in contempt of court and sentencing her to 48 hours incarceration in the county jail. We reverse.

The parties’ marriage was dissolved by a decree entered March 9, 1984. Mother was awarded custody of the five children, and father was given visitation rights “at reasonable times and places, including every other weekend from 6:00 p.m., Friday night until 6:00 p.m., Sunday evening and alternating holidays.”

On November 15, 1984, father commenced this proceeding, pro se, by filing a document entitled “Motion and Order For Show…