Palnik v. Crane

Citations

• 2019 Ohio 3364

Syllabus

Temporary spousal support child support civil contempt modification service hearing defense impossibility comply purge good faith local rules tax return income motion to dismiss. Because the trial court has yet to enter a final divorce decree, the validity of the temporary order is not subject to appellate review at this time. The trial court committed reversible error by considering the merits of a motion to show cause absent proper service. The motion was mistakenly delivered to an inaccurate address. The trial court did not commit reversible error by denying Husband's motion to dismiss for failure to comply with Loc.R. 20 of the Court of Common Pleas of Cuyahoga County, Domestic Relations Division. The trial court did not abuse its discretion in finding Husband in contempt for failing to comply with court's temporary support order. The purge conditions of the contempt judgment are not unreasonable or impossible for Husband to meet.