N.G. v. C.G., 1940 MDA 2015

Parents divorced; mother awarded primary physical custody and sole legal authority over education/daycare; father awarded partial physical custody. Child born Sept. 2010.
Father filed multiple contempt and custody-modification petitions (April–September 2015) alleging various violations by Mother (denial of vacation time, failure to provide babysitter/daycare contact info, missed calls, exclusion from events).
Several emergency petitions were denied as non-emergencies; some vacation time was later rescheduled by court order.
A hearing on Father’s contempt allegations was held October 8, 2015; the court found Mother "technically in contempt" for minor/isolated violations but declined to impose sanctions.
Father filed for reconsideration and appealed pro se. He also initially failed to timely file a Pa.R.A.P. 1925 concise statement but complied after court direction.
The Superior Court sua sponte considered appealability and concluded the contempt order was not final or collaterally appealable because no sanctions were imposed; appeal was quashed.

Issue	Father's Argument	Mother's Argument	Held
1. Is an appeal allowed when court finds contempt but imposes no sanctions?	An appeal should be permitted to challenge the court’s decision not to impose sanctions.	An order finding contempt without sanctions is not a final, appealable contempt order.	Finding of contempt without sanctions is interlocutory/nonfinal; not appealable.
2. Did the court abuse discretion by not imposing sanctions?	Court abused discretion because Mother violated custody orders on multiple occasions.	Violations were de minimis or excusable; sanctions unnecessary.	No review on merits—court lacked jurisdiction because order was nonfinal; failure to impose sanctions not immediately appealable.
3. Did the court improperly cut off Father’s cross-examination?	Hearing was ended abruptly, denying right to cross examine Mother.	(Not argued in detail in opinion.)	Not addressed on merits because appeal was quashed as nonappealable.
4. Did the court improperly address other custody issues while appeal pending?	Court exceeded scope by addressing custody issues without notice and despite pending appellate matter.	(Not argued in detail in opinion.)	Not reached; appeal dismissed for lack of jurisdiction.

Genovese v. Genovese, 550 A.2d 1021 (Pa. 1988) (contempt order without sanctions is not final and therefore not appealable)
Rhoades v. Pryce, 874 A.2d 148 (Pa. Super. 2005) (reiterating that contempt orders are interlocutory absent sanctions)
Foulk v. Foulk, 789 A.2d 254 (Pa. Super. 2001) (en banc) (collecting cases holding sanctions determine finality of contempt orders)
Wolanin v. Hashagen, 829 A.2d 331 (Pa. Super. 2003) (same principle that contempt findings without sanctions are nonfinal)