Behr v. Behr

I agree with the principles as articulated by the Majority to establish the elements of criminal contempt. I diverge, however, from the Majority’s application of the principles to the facts herein, and would afford deference to the trial court. Accordingly, I respectfully dissent, as I believe sufficient evidence existed to establish criminal contempt.

Appellant was involved in child support and custody proceedings with his former wife. At the conclusion of a hearing, Appellant left the courtroom leaving behind two boxes for his daughter to remove. The boxes were in the courtroom during the…