In re the Marriage of: Thomas Todd Reynolds v. Tricia Reynolds, 64 N.E.3d 829

Thomas Reynolds (Father) and Trida Reynolds (Mother) divorced in 2010; the decree required Father to make income/tax documents available upon written request. In 2013 the parties entered an agreed modification requiring quarterly income documentation and percentage-based payments.
Mother repeatedly requested Father’s tax/income documents for 2010–2013 (motions to compel in June and November 2014; inspections and follow-up requests were made). Father produced some but not all requested records.
Mother filed a Verified Motion for Rule to Show Cause (contempt) alleging Father’s failure to comply; the parties agreed to a summary proceeding before the trial court.
At the summary hearing the trial court found Father in indirect contempt for failing to provide the tax documentation, ordered production within 30 days, and awarded $3,000 of Mother’s attorney fees as sanctions.
The Court of Appeals reversed, holding the trial court failed to strictly comply with the rule-to-show-cause statute and did not afford Father an opportunity to purge contempt; the Indiana Supreme Court granted transfer.
The Indiana Supreme Court affirmed the trial court, holding (1) Mother’s motion provided sufficient notice, (2) Father waived objections to the summary format and the evidence supported contempt, and (3) the trial court was not required to offer a purge opportunity under these facts.

Issue	Mother’s Argument	Father’s Argument	Held
Whether Mother’s motion satisfied rule-to-show-cause notice requirements	Motion contained detailed factual allegations and incorporated the production requests—sufficient notice	Trial court failed to issue a proper rule to show cause; statute requires the court’s order to set forth facts	Motion was sufficient; strict statutory formality excused because Father had clear notice
Whether Father waived objections to summary proceeding and evidentiary sufficiency	Parties agreed to summary proceeding; record supports that some documents were not produced	Father contended a full evidentiary hearing was needed and that he did not willfully violate the decree	Father waived procedural objection by agreeing to summary proceedings; evidence supported contempt finding
Whether the trial court abused discretion in finding contempt and awarding fees	Contempt appropriate; court may award attorney fees for civil contempt	Father argued he merely made documents available or produced some documents and thus was not in contempt	No abuse of discretion; contempt and $3,000 fee award upheld
Whether the court was required to provide an opportunity to purge contempt	Not required here because no jail coercion, and purge opportunity is discretionary on proper showing	Court of Appeals said purge opportunity required under statute	Purge not required under these circumstances (no jail term; Father made no proper showing)

Steele‑Giri v. Steele, 51 N.E.3d 119 (Ind. 2016) (standard: contempt reviewed for abuse of discretion)
Witt v. Jay Petroleum, Inc., 964 N.E.2d 198 (Ind. 2012) (trial court contempt authority and review standard)
In re A.S., 9 N.E.3d 129 (Ind. 2014) (distinction between direct and indirect contempt)
In re Contempt of Wabash Valley Hosp., Inc., 827 N.E.2d 50 (Ind. Ct. App. 2005) (rule-to-show-cause statute fulfills due process notice and hearing requirements)
Bogner v. Bogner, 29 N.E.3d 733 (Ind. 2015) (summary proceedings and waiver for failure to contemporaneously object)
Crowl v. Berryhill, 678 N.E.2d 828 (Ind. Ct. App. 1997) (trial court authority to award attorney fees for civil contempt)
Deckard v. Deckard, 841 N.E.2d 194 (Ind. Ct. App. 2006) (civil contempt's coercive, not punitive, purpose)