Jerome v. Jerome

Appellant, Eric Pierre Jerome, challenges a trial court order in a dissolution action finding him in contempt and directing his incarceration until he complies with a prior support order. We reverse.

In Bowen v. Bowen, 471 So.2d 1274, 1278 (Fla.1985), the court specifically addressed the use of contempt proceedings in family support matters. The Bowen court receded from any language in its prior opinions suggesting that incarceration can be imposed upon a civil contemnor who lacks the present ability to pay the amount of arrear-age. Earlier, in Faircloth v. Faircloth, 339 So.2d 650 (Fla.1976),…