Crieg Alen Oster v. Consuelo Moreno Ratliff, 205 So. 3d 1149

Crieg Oster and Consuelo Ratliff divorced in 2007; Consuelo was awarded primary physical custody of two minor children, Patrick (b. 1991) and Maria (b. 1994).
In 2012 Patrick and Maria moved out of Consuelo’s home into a shared apartment, remained full-time students, and held full-time jobs; both received financial assistance from their parents.
Post-divorce disputes culminated in cross-petitions for citations of contempt: Crieg alleged Consuelo failed to pay one-half of vehicle costs, college expenses, and child support; Consuelo alleged Crieg failed to pay child support and one-half of medical expenses/insurance premiums.
At hearing, chancellor allowed Crieg to argue that the children were legally emancipated as of June 1, 2012; chancellor found they were not emancipated (Patrick not emancipated until his 21st birthday), did not hold Crieg in willful contempt, awarded Consuelo past and future child support as appropriate, and ordered Consuelo to pay one-half of certain vehicle costs.
Chancery court sanctioned Crieg for discovery violations and awarded Consuelo $2,500 in attorney’s fees; it did not award post-judgment interest on the money judgment.
The Court of Appeals affirmed the chancellor’s factual findings and sanctions but reversed and remanded on the failure to award post-judgment interest, directing interest be calculated on past-due support, insurance premiums, and attorney’s fees related to collection.

Issue	Ratliff's Argument	Oster's Argument	Held
Were Patrick and Maria legally emancipated on June 1, 2012?	They were not emancipated; remained full-time students and received parental support.	They were emancipated because they moved out, filed independent tax returns, had full-time jobs, and supported themselves.	Not emancipated on June 1, 2012; Patrick emancipated at 21. Court did not err.
Was Oster in willful contempt for failing to pay child support/insurance after June 1, 2012?	Yes; he stopped payments when children moved out.	No; his nonpayment was not willful—he believed custody obligations had changed and relied on extrajudicial arrangements.	Chancellor reasonably found no willful contempt; appellate court affirmed.
Should Ratliff have been awarded attorney’s fees beyond discovery sanction?	Yes; fees should be awarded because Oster was in contempt.	No; contempt not established, only fees for discovery sanction appropriate.	Only $2,500 awarded for discovery violations; no additional fees since no contempt.
Was the chancery court required to award post-judgment interest on the monetary judgment?	Yes; statute requires interest on judgments for past-due support and related amounts.	Issue waived or would be punitive; should not be awarded.	Error to deny post-judgment interest; reversed and remanded to calculate interest.

Lewis v. Pagel, 172 So. 3d 162 (Miss. 2015) (standard of review in domestic-relations matters and de novo review for legal questions)
Ellis v. Ellis, 840 So. 2d 806 (Miss. Ct. App. 2003) (contempt findings entitled to chancellor’s wide discretion; willfulness required for contempt)
Evans v. Evans, 75 So. 3d 1083 (Miss. Ct. App. 2011) (attorney’s fees may be assessed against a party found in contempt)
Mount v. Mount, 624 So. 2d 1001 (Miss. 1993) (authority on attorney’s fees in contempt contexts)
Caplinger v. Caplinger, 108 So. 3d 992 (Miss. Ct. App. 2013) (error as a matter of law for a chancellor not to award interest on a judgment for past-due support)