Carothers v. Carothers

MICHAEL A. WOLFF, Judge.

Introduction

This appeal raises two questions:(1) When is a judgment of contempt final for purposes of appeal?(2) Must the record include waiver of the right to counsel when the defendant in contempt is unrepresented?

*23Pamela Carothers was found in contempt of court for failing to satisfy a support judgment against her. She was not represented by counsel, and no waiver of her right to counsel appears in the record. Although she filed her notice of appeal within 10 days of being incarcerated, her appeal was dismissed. Her appeal, however, was filed timely. The judgment of…