Narrative Opinion Summary
The Supreme Judicial Court of Massachusetts adjudicated a case involving civil contempt judgments against a defendant who failed to comply with court-ordered child support and employment mandates. Initially, the defendant was held in contempt on July 18, 1986, for not securing a sales position similar to his previous employment, resulting in a six-month jail sentence, which was stayed during appeal. Subsequently, the defendant was again found in contempt on January 21, 1987, for not cooperating with the Family Service Office in job seeking, leading to a thirty-day jail sentence, also stayed pending appeal. The court consolidated the appeals, affirming the first contempt judgment but reversing the second. The original divorce case initiated in 1983 involved child support orders based on the defendant's earning capacity, which he failed to meet. The court emphasized that under General Laws c. 215, § 34, the burden was on the defendant to prove his inability to comply, which he did not fulfill. However, the second contempt adjudication was reversed due to the absence of a clear directive in the order to cooperate with the Family Service Office. Consequently, the court upheld the first contempt adjudication while reversing the second, reflecting the defendant's continued non-compliance with court orders.
Legal Issues Addressed
Burden of Proof in Civil Contempt Proceedingssubscribe to see similar legal issues
Application: In civil contempt hearings within the Probate and Family Court, the defendant must demonstrate an inability to comply with the order, which the defendant failed to do in this case.
Reasoning: General Laws c. 215, § 34 mandates that in civil contempt hearings within the Probate and Family Court, the defendant must prove their inability to comply with the relevant order or judgment.
Contempt of Court for Failure to Pay Child Supportsubscribe to see similar legal issues
Application: The defendant was found in civil contempt for failing to comply with court-ordered child support obligations, despite the court's determination of his ability to pay.
Reasoning: The defendant was initially found in civil contempt on July 18, 1986, for not securing a sales position akin to his prior role from 1964 to 1983, leading to a six-month jail sentence.
Reversal of Contempt Adjudication Due to Lack of Clear Ordersubscribe to see similar legal issues
Application: The court reversed the second contempt adjudication because the order to cooperate with the Family Service Office did not specify the required compliance actions.
Reasoning: The adjudication dated January 21, 1987, which found the defendant in contempt for allegedly violating an October 6, 1986, order to cooperate with the Family Service Office, was deemed invalid.