Jay S. Senatra v. Amy J. Senatra, 21-0171

Parties entered a stipulated dissolution decree in 2015 providing joint legal custody and joint physical care; parents later informally shifted to weekly Sunday exchanges with a midweek Wednesday visit when a parent did not have the children.
On August 4, 2020, Jay struck his then-15-year-old daughter G.E.S., damaging her school laptop; DHS investigated and issued a confirmed abuse report (not placed on central registry as it was deemed minor/isolate and unlikely to reoccur).
After the incident, G.E.S. refused to return to Jay’s home citing fear of further harm; Amy returned the children to Jay once after initial report but later did not return G.E.S. to Jay’s care while E.C.S. continued visits.
Jay filed an application for rule to show cause (contempt) on October 9, 2020, alleging Amy unlawfully withheld parenting time; a hearing was held January 11, 2021.
The district court found Jay failed to prove Amy acted with a bad or evil purpose and that G.E.S.’s refusal was tied to Jay’s conduct and the DHS finding; contempt was denied. The Court of Appeals affirmed and denied Amy’s request for appellate attorney fees.

Issue	Plaintiff's Argument (Jay)	Defendant's Argument (Amy)	Held
Whether Amy was in contempt for denying visitation	Amy willfully violated the joint physical-care decree by unilaterally withholding the children and did not seek modification	Amy withheld G.E.S. out of legitimate safety concerns after a DHS-confirmed abuse report and encouraged visitation; G.E.S.’s refusal stems from her father’s conduct	Affirmed: No contempt — Jay failed to prove willfulness/bad purpose beyond a reasonable doubt; denial tied to safety and child’s choice, not contempt
Whether Amy is entitled to appellate attorney fees	Opposed: statutory authority limits fee awards to found contemnors	Amy sought fees for defending on appeal	Denied: No statutory authority to award fees to a party merely defending against a contempt claim

In re Marriage of Hankenson, 503 N.W.2d 431 (Iowa Ct. App. 1993) (review standard where trial court refuses to hold party in contempt)
In re Marriage of Anderson, 451 N.W.2d 187 (Iowa Ct. App. 1989) (cited for appellate review principles in contempt matters)
Den Hartog v. City of Waterloo, 891 N.W.2d 430 (Iowa 2017) (reiterates requirement that contempt be proven beyond a reasonable doubt)
Reis v. Iowa Dist. Ct., 787 N.W.2d 61 (Iowa 2010) (discusses standard of proof in contempt-like proceedings)
In re Marriage of Swan, 526 N.W.2d 320 (Iowa 1995) (trial court has broad discretion in contempt matters)
Ary v. Iowa Dist. Ct., 735 N.W.2d 621 (Iowa 2007) (burden and elements required to prove contempt and willfulness)
Christensen v. Iowa Dist. Ct., 578 N.W.2d 675 (Iowa 1998) (ways an alleged contemner can show non-willfulness)
Farrell v. Iowa Dist. Ct., 747 N.W.2d 789 (Iowa Ct. App. 2008) (noncompliance with a decree may lack requisite willfulness for contempt)
In re Marriage of Ruden, 509 N.W.2d 494 (Iowa Ct. App. 1993) (limits of the court system in resolving intrafamily conflicts)