Carr v. Pridgen, 157 Idaho 238

Edgar and Carr are unmarried parents of minor D.C. and have ongoing custody disputes tied to their IN National Guard deployments.
The May 12, 2006 Order incorporated a Parenting Plan governing major decisions, including education and travel.
In 2010, after mediation failed, Edgar unilaterally enrolled D.C. at Pepper Ridge Elementary, without Carr’s assent or court resolution.
Carr filed a contempt motion in Nov. 2011 alleging two counts: (I) school enrollment contrary to the Parenting Plan and (III) travel to Mississippi before deployment.
The magistrate court found Edgar guilty on Counts I and III and sentenced accordingly; the district court affirmed, and Edgar appealed.
The Idaho Supreme Court reversed, vacated the convictions, and remanded for further proceedings consistent with due process and proper interpretation of the Parenting Plan.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Count I properly proven as willful contempt?	Carr alleged Edgar violated the May 12 Order by unilaterally enrolling D.C., claiming joint decision-making was required.	Edgar contends the May 12 Order did not clearly prohibit unilateral enrollment and that the parties could not reach an agreement.	Count I reversed; conviction vacated for lack of a clear, unequivocal order and proper notice.
Was Count III supported by evidence Edgar violated the Travel/Removal provision?	Carr argued Edgar denied travel to Mississippi in violation of the Parenting Plan’s travel/removal provisions.	Edgar contends the provision addressed removal from Idaho and evidence did not prove a violation of that clause.	Count III reversed; district court erred in applying the provision to predeployment travel; no clear violation.

State v. Rice, 145 Idaho 554 (2008) (criminal contempt requires a willful violation with clear order notice)
In re Weick, 142 Idaho 275 (2005) (review of contempt findings; sanctions reviewed for abuse of discretion)
Camp v. E. Fork Ditch Co., Ltd., 137 Idaho 850 (2002) (constitutional rights in non-summary criminal contempt proceedings)
Bailey v. Bailey, 153 Idaho 526 (2012) (appeals from contempt; review of district court decision; attorney fees)
Losser v. Bradstreet, 145 Idaho 670 (2008) (procedural framework for appellate review of district court decisions in contempt cases)
Pelayo v. Pelayo, 154 Idaho 855 (2013) (illustrates appellate review of contempt and related decisions)
Ross v. Coleman Co., Inc., 114 Idaho 817 (1988) (due process requires clear and unequivocal orders for contempt convictions)