Shebelskie v. Brown, 287 Va. 18

Betty Brown was ordered by the circuit court (April 26, 2011) to close on a property purchase and to pay Larry Brown attorney fees, costs (including $3,815.50) and an additional $12,500; the order did not specify the total fees, a payment deadline for the unspecified amounts, or the manner of payment for those amounts.
Betty closed on May 5, 2011 but did not immediately pay the unspecified sums; counsel proposed offsetting the sums against obligations Larry owed to Betty, which Larry rejected.
Larry filed a rule to show cause for contempt; Wright filed a written response (signed by Wright) arguing contempt requires an order with definite, express terms (citing Winn), and Shebelskie made similar oral arguments at the contempt hearing.
The circuit court found both Wright and Shebelskie violated Va. Code § 8.01‑271.1 (sanctions for baseless pleadings/motions) and ordered them jointly and severally to pay $12,605.33; the court treated their arguments as claiming interlocutory orders need not be obeyed.
The Virginia Supreme Court granted review and reversed: it held Shebelskie had not made an "oral motion" or signed the brief, and Wright’s written arguments were a reasonable legal position under existing contempt law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Shebelskie violated § 8.01‑271.1	Shebelskie argued Betty could not be held in contempt because the April order lacked definite terms	Shebelskie: he only made oral argument in response to Larry's motion and did not sign or make an oral motion under the statute	Reversed: Shebelskie did not sign the brief or make an "oral motion"; oral responsive argument is not an "oral motion" under § 8.01‑271.1
Whether Wright violated § 8.01‑271.1 by his signed brief	Wright argued contempt requires an express, definite command; an order that fails to fix amount/date/manner cannot sustain contempt	Larry argued the brief advocated disobedience and was not grounded in law	Reversed: Wright could reasonably, after inquiry, believe his contempt-related arguments were warranted by existing law (Winn, Petrosinelli)
Proper scope/meaning of "oral motion" in § 8.01‑271.1	N/A	Defendants: statute’s word "motion" has its ordinary meaning; not every oral argument equals an oral motion	Held that "motion" means an oral or written application requesting a specified ruling; responsive argument is not an "oral motion"

Winn v. Winn, 218 Va. 8, 235 S.E.2d 307 (1977) (contempt lies only for failure to obey an order's definite, express terms)
Petrosinelli v. People for the Ethical Treatment of Animals, Inc., 273 Va. 700, 643 S.E.2d 151 (2007) (a contempt finding requires an express command or prohibition in the order)
Gilmore v. Finn, 259 Va. 448, 527 S.E.2d 426 (2000) (sanctions under § 8.01‑271.1 reviewed for abuse of discretion; objective reasonableness standard)
Landrum v. Chippenham & Johnston‑Willis Hosps., Inc., 282 Va. 346, 717 S.E.2d 134 (2011) (describes when a court abuses discretion)
Lawlor v. Commonwealth, 285 Va. 187, 738 S.E.2d 847 (2013) (abuse‑of‑discretion review includes checking for erroneous legal conclusions)