Contempt • Custody Order • De Minimus Violations

Rehak v. Thompson, PICS Case No. 17-0772 (C.P. Allegheny Dec. 2, 2016) Hens-Greco, J. (11 pages).

Mother was not in contempt of court for de minimus custody order violations, including her failure to log the child's summer camp activity on a shared calendar and her occasional failures to have the child ready at the exact time scheduled for custody exchanges or telephone calls.

The parties were the parents of a nine-year-old son. Father appealed the court's order which denied his petition for contempt regarding mother's failure to comply with the terms of a custody order. On two prior occasions, father had filed contempt petitions containing similar allegations against mother, which the court had also denied. Hearings were held in those two prior matters, and the court found some de minimus noncompliance by mother, but not enough to rise to the level of contempt.