The Appellate Group

Civil Stalking Injunction

Thomas v. Thomas

Thomas v. Thomas, 2021 UT App 8 (Forster, J.)

Family Law; Contempt

The parties in this case, Father and Mother, were married with children, but following a divorce, the parties to agree to the appointment of a special master to resolve any related disputes. Mother filed a show cause motion, alleging that Father had repeatedly failed to comply with the special master’s orders. The district court agreed and held Father in contempt. On appeal, Father challenged whether failure to comply with a special master can result in contempt and whether the district court abused its discretion in its findings. The Utah Court of Appeals affirmed:

  • It was previously settled in Wight v. Wight, 2011 UT App 424 that violating orders of a special master can result in contempt. The court of appeals found no abuse of discretion, holding that the district court’s order was extensive and amply supported in the record.