Kimberly Sturgis v. Urian Sturgis Sr, 326163

Kimberly Sturgis was held in contempt by the Wayne Circuit Court for repeatedly failing to comply with court orders requiring mental-health therapy for her children and a psychological evaluation for her son.
Defendant moved for a show-cause order; Sturgis was personally served and show-cause hearings occurred on January 28 and February 4, 2015.
The trial court found Sturgis in civil contempt and sentenced her to two days in jail to coerce compliance; she served those two days and was released on the date of a scheduled mental-health appointment.
On appeal the Court of Appeals remanded for supplemental findings to clarify whether the contempt was criminal or civil, factual findings, and whether Sturgis served the sentence.
The trial court’s supplemental order clarified the proceedings were civil, reiterated the factual basis for contempt (continued noncompliance and perceived disingenuous excuses), and confirmed Sturgis served two days in jail.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether contempt proceedings violated due process (right to counsel and adequate notice)	Sturgis contends she was denied counsel and sufficient notice to prepare a defense	Trial court provided personal service, time to prepare, and sought to secure appointed counsel; hearings afforded opportunity to present defense	No plain error; due process satisfied — civil contempt procedures followed (notice, oath, hearing)
Whether the contempt was criminal or civil in nature	Sturgis argued (implicitly) that procedural protections were lacking if criminal	Court and record show the proceedings aimed to coerce compliance, not punish	Proceeding was civil contempt
Whether contempt finding required willfulness	Sturgis argued court erred by effectively finding willful disobedience	Defendant relied on pattern of noncompliance and court credibility findings	Willfulness not required for civil contempt; even if implied, trial court’s credibility-based finding was not clearly erroneous
Whether the sanction (two-day definite jail term) was improper for civil contempt	Sturgis suggested sanctions or process irregularities made punishment improper	Court timed the definite term to coincide with the scheduled mental-health appointment, implicitly making release conditional on that compliance	No reversible error; definite two-day term aligned with next compliance opportunity and did not require reversal

Arbor Farms, LLC v GeoStar Corp, 305 Mich App 374 (contempt review: abuse of discretion standard; definition and purpose of contempt)
In re Contempt of Henry, 282 Mich App 656 (due process and plain-error standard in contempt proceedings)
In re Contempt of Dudzinski, 257 Mich App 96 (courts must use contempt power with restraint; sanctions must be least necessary)
Porter v Porter, 285 Mich App 450 (distinguishing criminal vs civil contempt; differing due-process protections)
In re Contempt of Auto Club Ins Ass'n, 243 Mich App 697 (requirement of hearing when contempt occurs outside court’s view; MCR 3.606 procedures)
In re Contempt of Robertson, 209 Mich App 433 (statutory and inherent contempt authority)
Davis v City of Detroit Fin Review Team, 296 Mich App 568 (willfulness not required for civil contempt finding)
In re Contempt of United Stationers Supply Co, 239 Mich App 496 (civil contempt may be based on disobedience without specific willfulness finding)
In re Moroun, 295 Mich App 312 (discussion of indefinite vs definite civil contempt sentences and conditional confinement)
Turner v Rogers, 564 US 431 (U.S. Supreme Court discussion of counsel in civil contempt contexts arising from nonpayment cases)