Department of Revenue Child Support Enforcement v. Grullon
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In Father's appeal from a civil contempt order and subsequent judgment on a complaint for unpaid child support filed by Mother, the Supreme Judicial Court held that the judge abused her discretion in holding Father in civil contempt.
Mother filed a pro se complaint for civil contempt in the probate and family court alleging that Father, the noncustodial parent, was $3,690 in his child support payments. Father filed an answer and counterclaim for modification, claiming that his past incarceration and subsequent difficulty obtaining employment made past and future payments at the set rate impossible. The judge held Father in contempt and then entered judgment on Father's complaint for modification, reducing his ongoing child support obligation to his requested amount. The Supreme Court vacated the civil contempt judgment against Father, holding (1) Father's case should not have reached the civil contempt hearing stage, (2) the Department of Revenue failed to follow the Federal regulations and its own procedures in failing to assist Father, and (3) the judge failed to provide Father with sufficient procedural safeguards.
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