Contempt/Enforcement of Orders

March 31st, 2026

Court of Appeals finds agreement to pay agreement to pay half of college expenses was not ambiguous

The March 18, 2026, Court of Appeals opinion in Fennell v. Fennell, affirmed a family court order finding Father in contempt for not paying one-half of daughter’s college tuition and expenses and requiring him to pay Mother’s attorney’s fees. As part of the parties’ divorce and marital settlement agreement, “[b]oth parties agree[d] to contribute equally to […]

Contempt/Enforcement of Orders

August 24th, 2023

Court of Appeals reverses family court and grants Wife relief from her contempt petition despite not finding Husband in contempt

In the August 23, 2023 opinion in Moore v. Smith, 441 S.C. 261, 892 S.E.2d 552 (Ct.App. 2023), the Court of Appeals reversed the family court’s refusal to require Husband to hold Wife harmless on a note encumbering the marital home despite affirming the family court’s finding that Husband was not in contempt on that […]

Contempt/Enforcement of Orders

September 14th, 2022

Court of Appeals publishes opinion on the inapplicability of status of limitations to support obligations

On September 7, 2022, the Court of Appeals published an opinion in Holland v. Holland, 438 S.C. 69, 881 S.E.2d 766 (Ct.App. 2021), reversing the family court’s determination that Wife’s attempt to collect a child support obligation in 2017 that ended in 2004 was barred by South Carolina’s statute of limitations.  The opinion is curious […]

Contempt/Enforcement of Orders

August 10th, 2022

Court of Appeals reverses child support payment finding by rejecting family court’s credibility determination

Just this May I lectured on how de novo review made appealing family court orders more viable.  In the materials, I noted six post-Lewis reported appeals in which the family court was reversed, at least in part, because the appellate court rejected the family court’s credibility determinations. The August 10, 2022, Court of Appeals opinion […]

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