In re the Marriage of Miller

Husband appeals from a supplemental judgment holding him in contempt for failing to comply with his obligations under the general judgment dissolving his marriage. He concedes that he was in contempt, but contends that the trial court erred in confining him for 10 days because confinement for a definite period of time is not an available sanction for remedial contempt. We agree and reverse and remand.

Following husband’s failure to comply with the terms of the dissolution judgment, wife filed a motion to hold husband in remedial contempt. One of the remedial sanctions wife sought was…