Rosser v. Rosser, 438 P.3d 1047

Ronald and Holly Rosser mediated their divorce and signed a Mediation Agreement allocating the 2015 IRS liability 50/50; Holly paid her half, Ronald did not.
After mediation, the parties executed a stipulated decree of divorce (Decree) that (unlike the Mediation Agreement) stated Holly "shall be solely entitled to receive any refund resulting from the amended returns, and shall also be responsible to pay any tax liabilities resulting to any of the Parties for the year 2015."
An amended 2015 return was prepared (mistakenly showing a refund); parties signed it; the amended return was later found inaccurate and the parties owed ~$7,175 for 2015 taxes.
Holly filed an order to show cause alleging Ronald defrauded her and asking the court to hold him in contempt for failing to pay his share; Ronald filed a reciprocal motion about unpaid rebates.
The district court found Ronald in contempt for "deliberate deceit and failure to act as agreed" at mediation, awarded Holly roughly $15,000 plus $4,000 in fees, offsetting rebate obligations; Ronald appealed.
The Court of Appeals held that statutory contempt was unavailable because (1) Ronald's alleged deceit was directed at Holly, not the court, and (2) the Decree on its face placed responsibility for any 2015 tax liabilities on Holly, so Ronald had no contemptuous disobedience of a court order.

Issue	Holly's Argument	Ronald's Argument	Held
Whether district court validly held Ronald in statutory contempt for deceit under § 78B-6-301(4)	Ronald deceived Holly about paying his share and thus engaged in deceit tied to the action, fitting subsection (4)	Subsection (4) applies only to deceit on or misuse of court proceedings; Ronald's alleged deceit was directed at Holly, not the court	Subsection (4) requires deceit directed to or abusing the court's process; Ronald's conduct was not deceit upon the court, so contempt under (4) fails
Whether district court validly held Ronald in contempt for disobeying a court judgment/order under § 78B-6-301(5)	Ronald violated the parties' agreements (mediation and equities) and thus disobeyed a court-ordered result	The Decree—a court order—expressly assigned responsibility for any 2015 tax liabilities to Holly, so Ronald did not disobey the Decree	The Decree unambiguously made Holly responsible for 2015 tax liabilities; Ronald's nonpayment did not violate a court order, so subsection (5) does not apply

LD III LLC v. Davis, 385 P.3d 689 (Utah Ct. App. 2016) (standards for appellate review of contempt findings)
Chen v. Stewart, 123 P.3d 416 (Utah 2005) (courts possess both statutory and inherent contempt powers)
Thayer v. Washington County School Dist., 285 P.3d 1142 (Utah 2012) (commonsense approach to statutory interpretation; construing words by neighbors)
Mind & Motion Utah Investments, LLC v. Celtic Bank Corp., 367 P.3d 994 (Utah 2016) (plain-meaning rule and when contract language is ambiguous)
Bhongir v. Mantha, 374 P.3d 33 (Utah Ct. App. 2016) (examples of contempt for false statements to the court)