Lawrence S. Ireland v. Brooke (Ireland) Tardiff, 107 A.3d 618

Lawrence Ireland and Brooke Tardiff divorced in August 2012; the judgment (based on a settlement) required Ireland to pay Tardiff $50,000 within 120 days, which after other offsets resulted in a required payment of $42,150. Ireland did not appeal the divorce judgment.
By March 2013 Ireland had paid only $0 (until later sending $300) and had made multiple discretionary gifts/loans from personal/business accounts totaling nearly $2,000 after the judgment.
Tardiff obtained an enforcement order in April 2013 requiring payment of $42,150 within 30 days; Ireland still largely failed to pay and Tardiff moved for contempt in July 2013.
After a January 2014 hearing, the District Court found Ireland in civil contempt by clear and convincing evidence, sentenced him to 90 days jail with a purge option of four payments of $10,537.50 between April and November 2014, and found he had the ability to pay at least in part (citing business receipts, assets, and discretionary spending).
Ireland sought reconsideration and additional findings; the court made further findings about Ireland’s receipts, assets (vehicles/equipment valued at least $88,700), and spending patterns, denied relief, and Ireland appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court properly found Ireland in civil contempt for failing to pay the divorce judgment	Tardiff: Ireland willfully failed to comply and had ability to pay at least in part; contempt appropriate	Ireland: lacked ability to make the four scheduled payments within nine months; court abused discretion	Court: Affirmed — findings supported by competent evidence; contempt finding sustained
Whether the court could require use of business/assets to satisfy the marital-property payment	Tardiff: business and other assets are part of marital property and may be used to satisfy the judgment	Ireland: challenged ability to liquidate assets/pay the ordered installments	Court: Affirmed — court within discretion to require using business/assets to satisfy the marital division

Murphy v. Bartlett, 86 A.3d 610 (Me. 2014) (standard of review for factual findings in civil contempt)
Lewin v. Skehan, 39 A.3d 58 (Me. 2012) (contempt requires proof of failure to comply and present ability to comply)
Efstathiou v. Efstathiou, 982 A.2d 339 (Me. 2009) (contemnor must comply to the fullest extent possible; partial payment obligation considered)
Dargie v. Dargie, 778 A.2d 353 (Me. 2001) (business interest may be treated as marital property subject to division/payment)
Starrett v. Starrett, 101 A.3d 435 (Me. 2014) (harmless-error inquiry for appellate review)