Byrne v. Byrne

The former wife appeals an order holding her in contempt for failing to pay mortgages on the former marital home, and appointing a receiver to collect rental income from the former marital home in order to pay the mortgages. She argues, among other things, that contempt cannot be used to enforce equitable distribution, and that the former husband lacked standing to seek appointment of a receiver. We agree on these points and find no need to address the former wife’s remaining arguments which are either moot or lack merit.

The parties divorced in 2010. Under the final judgment of dissolution of…