S.H.B. v. M.W.L., 2019 Ohio 3036

In June 2014 S.H.B. obtained an ex parte domestic violence civil protection order (CPO) against M.W.L.; a full CPO later issued and remained in effect through 2020.
In June 2015 a magistrate found M.W.L. in contempt for tracking S.H.B. with a GPS and for orchestrating contact, and imposed a sentence: 30 days jail on each of two contempt findings (or 200 hours community service per finding), or until purge; purge required enrollment/completion of a Batterers’ Intervention Program and a psychiatric/psychological evaluation with compliance with recommendations.
In April 2016 the trial court modified the sentence to a single 30‑day jail term (or 200 total community‑service hours), leaving the remainder of the purge conditions intact; M.W.L. did not appeal that modification.
Between 2016–2018 S.H.B. filed motions to show cause and for imposition; at a May 2018 purge hearing M.W.L. admitted he had not enrolled in the intervention program, had not completed a psychological evaluation, and had not documented completion of 200 community‑service hours (though he testified he did some synagogue service and believed he could elect community service in lieu of other purge conditions).
The trial court found M.W.L. had not purged contempt and ordered execution of the 30‑day jail sentence; M.W.L. appealed, arguing the court should have allowed him to complete community service and that purge conditions were ambiguous/unenforceable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused discretion by imposing 30‑day jail rather than permitting completion of 200 community‑service hours	S.H.B.: court may enforce suspended sentence because M.W.L. failed to satisfy purge conditions	M.W.L.: he elected community service, began performing it, and should be allowed to finish the 200 hours in lieu of jail; purge conditions ambiguous/no deadline	Trial court did not abuse discretion; M.W.L. failed to prove he completed or documented 200 hours and did not meet purge conditions, so jail execution proper
Whether the contempt order was ambiguous or required a deadline for community service	S.H.B.: purge order was clear and enforceable; any challenge to wording was untimely after appeals exhausted	M.W.L.: order ambiguous (he read “or” as allowing choice between community service or purge requirements) and lacked deadline for service, making compliance impossible	Order was unambiguous as to purge requirements; any challenge to wording was untimely; reasonable time to complete community service may be inferred and nearly three years was unreasonable; therefore no ambiguity defense

Blakemore v. Blakemore, 5 Ohio St.3d 217 (defining abuse of discretion standard)
Pugh v. Pugh, 15 Ohio St.3d 136 (civil contemnor may purge himself; "keys of his prison in his own pocket")
Brown v. Executive 200, Inc., 64 Ohio St.2d 250 (same principle regarding civil contempt and purge)
Liming v. Damos, 133 Ohio St.3d 509 (purge hearing limited to whether contemnor complied with purge conditions)
Docks Venture, L.L.C. v. Dashing Pacific Group, Ltd., 141 Ohio St.3d 107 (reiterating that purge‑hearing scope is compliance with purge terms)