In re W.R.P., 2013 Ohio 702

CSEA filed a motion to show cause for Phillips's failure to pay court-ordered child support (Apr 27, 2011).
A merits hearing was held (Feb 27, 2012); magistrate found Phillips in contempt, imposed a 15-day suspended sentence, and set up purge and a purge-review hearing for Aug 22, 2012.
The March 26, 2012 contempt judgment awarded purge conditions and required continued support with arrears, plus a purge amount of $550 to be paid within 120 days.
At the Aug 22, 2012 purge-review, CSEA showed Phillips failed purge; the court, over objection, found he had purged and vacated the March 26, 2012 contempt entry (Sept 21, 2012).
CSEA appeals the sua sponte vacatur and the purge finding; the appellate court reverses and remands, awarding costs to CSEA.
The decision treated a contempt judgment with purge as final and subject to Civ.R. 60(B) relief, and held the purge finding not supported by the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court could sua sponte vacate its contempt judgment.	CSEA—final contempt entry cannot be vacated without Civ.R. 60(B) relief.	Phillips—court had authority to vacate due to purge findings.	Yes; court abused discretion by vacating without Civ.R.60(B).
Whether Phillips purged the contempt as found by the trial court.	CSEA—evidence shows purge condition not satisfied.	Phillips—purge accomplished via monthly payments.	No; record does not support purged contempt; abuse of discretion.

State v. Thomas, 2012-Ohio-5077 (8th Dist. 2012) (abuse of discretion and finality principles in vacating judgments)
In re: R.T.A., 2012-Ohio-5080 (8th Dist. 2012) (contempt orders and finality; purge proceedings)
In re: M.W., 2013-Ohio-170 (8th Dist. 2013) (purge findings must be supported by evidence; abuse when not)
Kapadia v. Kapadia, 2012-Ohio-808 (8th Dist. 2012) (stay or modification of judgments; purge-related lethality)
Jacobson v. Starkoff, 2002-Ohio-7059 (8th Dist. 2002) (finality of contempt orders and purge considerations)