Puff v. Puff
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In this postdissolution matter the Supreme Court affirmed the judgment of the Appellate Court reversing the decision of the trial court granting Defendant's motion for sanctions and for contempt, holding that there was no basis to support the award of attorney's fees and costs.
This matter stemmed from the parties' oral stipulation following a motion for modification of alimony and the trial court's adoption of that stipulation as a court order. Subsequent litigation efforts saw Defendant attempting to carry the order into effect and Plaintiff challenging the order. At issue was the court's decision to grant Defendant's postjudgment motion for sanctions and for contempt and awarding Defendant the litigation expenses he had incurred following the entry of the order adopting the stipulation. The Appellate Court reversed the trial court's judgment of contempt. The Supreme Court affirmed and further concluded that the sanction for litigation misconduct must be reversed, holding that, insofar as the award was based on contempt, it could not stand on any of the grounds articulated by the trial court, and insofar as the award was based on litigation misconduct, it lacked the requisite findings.
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