Koehler v. Allen, 466 P.3d 738

Koehler obtained a temporary civil stalking injunction against Allen, served May 13, 2016, prohibiting any direct or indirect contact and stating the order would last three years unless changed by the court.
Allen did not request a timely hearing (within 10 days); he later requested a hearing but no hearing was held and no court order revoked or modified the injunction.
In 2017 Allen was criminally charged for contacting Koehler and entered a plea-in-abeyance; he acknowledged the factual basis that he had contacted her despite the injunction and was ordered not to contact her for one year as a term of the plea agreement.
On December 21, 2018 Allen emailed Koehler; he later claimed he did not remember sending it and asserted he had been taking trazodone and Unisom and may have been asleep or intoxicated.
The district court found by clear and convincing evidence that Allen knew of the injunction and had the ability to comply, and ultimately entered contempt sanctions after a written ruling that concluded Allen either acted intentionally or was voluntarily intoxicated when he sent the email.
On appeal, the court affirmed the finding of knowledge but reversed and remanded because the district court failed to make an explicit finding whether Allen acted intentionally (it instead made an alternative finding that he acted intentionally or was voluntarily intoxicated).

Issue	Koehler's Argument	Allen's Argument	Held
Whether Allen knew he was subject to the injunction on Dec. 21, 2018	Allen received and was served with the injunction and later criminal proceedings confirm notice	His attorney misinformed him; he believed the injunction was dismissed and relied on subsequent plea terms	Affirmed: Court reasonably found Allen knew the injunction was in effect
Whether Allen intentionally violated the injunction (and whether voluntary intoxication negates intent)	Email content and timing show intentional contact in violation	He was voluntarily intoxicated (trazodone + Unisom) and lacked the capacity to form intent	Reversed & remanded: trial court did not make the explicit finding on intent required for civil contempt; remand to determine if intent was proved

Von Hake v. Thomas, 759 P.2d 1162 (Utah 1988) (establishes three-element test for contempt: knowledge, ability, intentional failure to comply)
State v. Hurst, 821 P.2d 467 (Utah Ct. App. 1991) (requires explicit findings on contempt elements)
State v. Bell, 380 P.3d 11 (Utah Ct. App. 2016) (explains when voluntary intoxication may negate required mental state)
In re D.V., 265 P.3d 803 (Utah Ct. App. 2011) (bench-trial sufficiency review standard)