On January 6, 2023, the Idaho Supreme Court issued its decision in Katseanes v. Katseanes. The decision addresses the enforceability of a trial court’s oral rulings and appellate review of criminal sanctions for contempt of court.
The facts. As part of a property settlement in a divorce, Jeff agreed to pay spousal support, which he failed to do. Judy filed suit to enforce the obligation. The trial court granted Judy a judgment of $90,633. Judy then asked the trial court for a Qualified Domestic Relations Order (“QDRO”) ordering Jeff to pay her out of his 401(k). The trial court orally granted Judy’s request, assigning her Jeff’s 401(k) up to $90,633. But before the trial court entered the written QDRO, Jeff withdrew all the 401(k) funds. That led Judy to seek the return of the funds and an accounting. The trial court agreed and ordered Jeff to return the funds and provide an accounting by a date certain. When Jeff did not provide the accounting, Judy moved to compel and for criminal sanctions for contempt of court. The trial court granted the motions and imposed a sanction on Jeff of five days in jail. In addition, after learning that Jeff paid his attorney from funds taken from the 401(k), the trial court ordered disgorgement of the fees. Jeff appealed.
The issues. The appeal arose from the trial court’s order holding Jeff in criminal contempt and the order of disgorgement. Before addressing the orders, the Court resolved the “initial question” of whether the trial court’s oral ruling granting the QDRO (which, again, assigned Jeff’s 401(k) to Judy) was valid and enforceable before it was signed. Important here, Jeff defended his withdrawal of the 401(k) funds because he did so before the trial court entered the written QDRO.
The result. The Court held that the trial court’s oral ruling granting Judy the QDRO was effective when it was ordered from the bench. The Court also affirmed the trial court’s order holding Jeff in criminal contempt and the order of disgorgement.
- Not surprisingly, the Court held that oral orders are entitled to the same force and effect between the parties to the lawsuit as an order reduced to writing. Despite observing “this is a clear point of law,” the Court explained that oral rulings are legitimate and complete when pronounced, even if not later memorialized in writing. The Court emphasized that the case was not about a final judgment, which must be reduced to writing to start the 42-day clock for filing a notice of appeal
- The Court also addressed the standard of review for a trial court’s finding of criminal contempt. The Court reviews the trial court’s conclusion of guilt beyond a reasonable doubt based on the substantial evidence standard. The trial court’s sanction, however, is reviewed under an abuse of discretion standard.
- A violation of a trial court’s order must be willful to justify an order of criminal contempt. The Court noted that it was “mindful” of the fact that Jeff was likely following the advice of his counsel in failing to comply with the order to provide an accounting of the funds. Even so, the Court found that Jeff, as the client, ultimately bore the burden of complying with the trial court’s order.