Ford v. HannaAnnotate this Case
In 2005, Robert Hanna and Kelli Ford were divorced in Gwinnett County. Hanna later moved to DeKalb County, and in 2011, Ford filed a petition in DeKalb County to modify their divorce decree with respect to child support and visitation. At the same time, Ford also filed a motion in DeKalb County for contempt, alleging that Hanna had failed to pay child support due under the decree. Hanna moved to dismiss the motion for contempt for want of jurisdiction, and the DeKalb County court granted his motion, citing the general rule that contempt of a decree ordinarily can be punished only by the court that rendered the decree. The DeKalb County court distinguished "Buckholts," reasoning that Buckholts was limited to counterclaims for contempt. Ford appealed, contending that the DeKalb County court had jurisdiction to entertain her motion for contempt. Upon review, the Supreme Court agreed, and reversed the dismissal of the motion for contempt.