Neely v. Neely (Tennessee 2019)

A contempt finding has four elements, one of which is a finding that the parent willfully didn’t pay the child support order. A contempt order must specifically address each element. After a series of motions, the chancery court entered an order finding the father in contempt for failure to pay support. The father appealed, arguing the court failed to hold an evidentiary hearing or give him an opportunity to contest the motion. The court of appeals reversed, finding that the order didn’t contain a sufficient finding of willfulness. The court of appeals held these findings provide the basis for the decision.