Slane v. Adams
Annotate this CaseDefendant-Respondent-Appellant Stephen Adams appealed a district court judgment that upheld a magistrate judge's order that dismissed his motions to modify child custody and child support. Defendant's had been held in contempt for failing to make one child support payment. He was unable to purge the contempt by paying all delinquent child support payments for reasons he said were beyond his control. A court can impose a criminal contempt sanction in nonsummary contempt proceedings only if the contemnor has been afforded the federal constitutional rights applicable to criminal contempt proceedings. The magistrate held that it could refuse to hear the Father's motions because he was unable to purge the contempt and could not prove that his inability was due to circumstances beyond his control. The district court held that refusal to hear the Father's motions was a permissible criminal contempt sanction. Idaho Code section 7-610 does not authorize denial of access to the courts as a criminal contempt sanction. Therefore, the district court erred in affirming the magistrate's order on the ground that it was a permissible criminal contempt sanction. The Supreme Court held that the district court erred in affirming the magistrate court's order. In addition, the Supreme Court held that refusal to hear a motion and dismissal of a motion that the contemnor did not purge the contempt violates Article I, Section 18 of the state constitution. The district court was reversed and the case remanded.
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