Court Orders • Contempt • Sanctions • Appealability • Abuse of Discretion

N.A.M. v. M.P.W., PICS Case No. 17-1299 (Pa. Super. Aug. 7, 2017) Ford Elliott, P.J. (12 pages).

Trial court correctly held that mother was in contempt of the court's order but erred in not imposing sanctions for mother's repeated, flagrant and ongoing contempt of orders related to child custody because no sanctions for flagrant abuse of court orders was an a abuse of discretion and father could challenge the order as a collateral order. Reversed in part and affirmed in part.

Parents contested custody of children for years before court awarded sole legal custody and primary physical custody to father and partial physical custody to mother. Father filed a contempt petition against mother alleging violations of court orders with respect to attendance at religious events and interference with education and his custodial time. Father alleged that mother refused to take child to religious school for a service, prevented father from attending a student led parent-teacher conference and interfered with father's custody at child's sports events. The trial court found that mother was in contempt but did not impose sanctions. Father challenged the lack of sanctions.