Butler v. Butler, 443 S.W.3d 585

Civil-judgment awarded to Butler for alimony, insurance, and child-support arrearages; contempt found against Gladwin with six-month purge period or incarceration.
District court/appeals reviewed alimony reduction, offset defense, and unclean-hands issue; judgment affirmed.
Parties had multiple prior orders and settlements governing alimony, child support, and debts.
Court denied appellant’s offset and alimony-reduction claims and held appellant in contempt for nonpayment.
The opinion includes a dissent arguing contempt order not final and appealable under Rule 2(a)(13).
Court referenced evidence credibility and discretion in equity proceedings while applying standards for contempt and modification

Issue	Plaintiff's Argument	Defendant's Argument	Held
Contempt finality and appealability	Butler contends contempt order final via six-month purge.	Gladwin argues order not final; seeks appellate review under Rule 2(a)(13).	Order deemed final; appealable contempt order affirmed.
Change in circumstances for alimony modification	Butler claim of increased need and higher income for modification.	Gladwin asserts no change in income; settlement terms not modifiable.	No abuse of discretion; modification denied.
Offset against alimony for repairs and mortgage	Butler seeks set-off for repairs and mortgage-related payments.	Gladwin contends insufficient evidence; contract allocated maintenance to appellant.	No clear error; offset denied.
Unclean hands doctrine applicability	Butler argues no improper conduct by Butler; focus on payments.	Gladwin asserts appellant’s conduct barred relief.	No clear error; clean-hands defense not established.

Ward v. Ward, 434 S.W.3d 923 (Ark. 2014) (civil contempt standard of review)
Henry v. Eberhard, 832 S.W.2d 467 (Ark. 1992) (partial suspension of contempt is not a remission)
Griffith v. Griffith, 283 S.W.2d 340 (Ark. 1955) (inability to pay as defense in contempt for money payments)
Duncan v. Duncan, 383 S.W.3d 833 (Ark. 2011) (equity/apportionment review in offset context)
Delacey v. Delacey, 155 S.W.3d 701 (Ark. App. 2004) (factors for alimony modification; discretionary)