Bullock v. Bullock (Wyoming 2014)

A civil contempt order must be supported by clear and convincing evidence. Clear and convincing evidence is “evidence that would persuade a finder of fact that the truth of the contention is highly probable.”  The elements of civil contempt are: “1) an effective court order that required certain conduct by the alleged contemnor; 2) the contemnor had knowledge of the order; and 3) the alleged contemnor disobeyed the order.” Once these elements are proven, the burden shifts to the person charged with contempt to show he or she was unable to comply.

This Court does not interfere with an order holding a party in civil contempt of court in a domestic relations case “absent a serious procedural error, a violation of a principle of law, or a clear and grave abuse of discretion.” In reviewing the exercise of a district court’s broad discretion under its contempt powers, we must determine whether the court reasonably could have concluded as it did.

Bullock v. Bullock, 2014 WY 131, 336 P.3d 136 (Wyo. 2014).pdf