Hanshaw v. Hanshaw, 55 So. 3d 143

Chancery court ordered equitable division and sale of the marital home with a deadline (Sept 21, 2004; closing set for Sept 30, 2004, later Oct 5, 2004).
Shirley arranged a move but canceled the moving service; she did not vacate the home by the court-ordered deadline.
On Oct 5, 2004, the chancellor ordered Shirley to vacate by 2:00 p.m.; she failed to leave.
Larry filed a contempt motion Oct 6, 2004; the court imposed a $12,000 contempt fine, paid from Shirley's share of the proceeds.
Shirley challenged lack of notice/hearing; the chancellor held her general appearance had waived jurisdictional defects.
The Court of Appeals reversed the contempt ruling on notice issues; Supreme Court granted certiorari and held no proper notice was given, vacated the Court of Appeals decision, reversed the contempt finding, and remanded for contempt proceedings with proper Rule 81(d) notice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there jurisdiction to enter contempt without proper Rule 81 notice?	Hanshaw argued lack of proper notice under Rule 81(d).	Hanshaw argued the chancellor had authority despite defects.	Yes, improper notice voids contempt; remand for proper notice.
Was the contempt penalty properly imposed and characterized as civil?	Hanshaw claimed improper calculation and improper award of penalties.	Hanshaw contends civil-contempt framework applied; award should reflect damages and fees.	Penalty improper without damages/fees finding; remand for civil-contempt calculation.

Isom v. Jernigan, 840 So.2d 104 (Miss.2003) (recognizes Rule 81 notice requirement in contempt actions)
Dennis v. Dennis, 824 So.2d 604 (Miss.2002) (contempt proceedings require proper notice and hearing)
Shavers v. Shavers, 982 So.2d 397 (Miss.2008) (Rule 81(d) notice required in contempt actions)
Vincent v. Griffin, 872 So.2d 676 (Miss.2004) (continuing jurisdiction does not waive Rule 81 summons)
Weeks v. Weeks, 556 So.2d 348 (Miss.1990) (reversal where proper notice not given in contempt case)
Purvis v. Purvis, 657 So.2d 794 (Miss.1994) (civil-contempt framework; damages and fees; manifest-error standard)
Moulds v. Bradley, 791 So.2d 220 (Miss.2001) (criminal contempt requires heightened safeguards)
In re Williamson, 838 So.2d 226 (Miss.2002) (procedural safeguards for criminal contempt)
Common Cause of Miss. v. Smith, 548 So.2d 412 (Miss.1989) (purge by payment of costs and compliance in civil contempt)
Corporate Mgmt., Inc. v. Greene County, 23 So.3d 454 (Miss.2009) (awards to prevailing party when misconduct caused unnecessary expenses)
Wyssbrod v. Wittjen, 798 So.2d 352 (Miss.2001) (civil-contempt framework and damages/fees considerations)