State ex rel. Daly v. Snyder

The State appeals a superior court order finding that incarceration was not one of the remedies available under the court’s contempt powers to enforce payment of arrearages owed for child support when there is no current, ongoing child support obligation. Because the purpose of incarceration is to compel compliance with a court order and not imprisonment for debt, we hold that incarceration for an arrearage-only case is constitutional, and reverse.

I

Melanie Snyder was born in 1983. In 1987, the superior court entered a default judgment against Marshall Snyder establishing his paternity. The…