In a recent decision by the Pennsylvania Supreme Court, authored by the late Chief Justice Max Baer, in the case of Commonwealth of Pennsylvania v. Stevenson, __ A.3d __, No. 21 WAP 2021 (Pa. April 12, 2022), the Pennsylvania Supreme Court addressed the issue of notice in a protection from abuse indirect criminal contempt case. Protection from abuse matters begin as civil cases. However, if the protection from abuse order is violated, the commonwealth may institute a criminal proceeding for indirect criminal contempt. If the commonwealth is successful, and the defendant is convicted, the defendant will suffer a criminal sentence, which may include probation or incarceration for up to six months.