State v. L.A., 245 P.3d 213

The juvenile court placed C.A. on probation on April 18, 2009 with the probation order directing the parents to participate in the program and comply with conditions.
The order required parents to notify the probation department of violations, attend meetings, authorize home searches, be financially responsible, and not modify the probation terms.
Probation Officer Brehm detected a positive marijuana urinalysis for C.A. on April 16 and directed Mother to bring C.A. to detention the next morning, warning of a warrant.
On April 17, Mother attempted to locate C.A. but he was in a school assembly; Brehm pressed for detention, stating a warrant had been issued.
By April 21, C.A. had not been detained; Father was directed to take him, but delays occurred due to other appointments; eventually C.A. was taken to detention.
The juvenile court found Mother in contempt for failing to transport C.A. to detention, fined her, and suspended a jail sentence; the court declined to find Father in contempt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence shows Mother knew she violated the order	Mother argues she did not know the directive implicated the 'meetings' clause.	Mother contends the order was not specific enough to require detention transport under the meeting clause.	No; knowledge not proven due to vague order language and lack of notice that 'attend meetings' included detention transport.
Sufficiency of the probation order's 'meetings' and 'transportation' provisions	The order required attendance at meetings and transportation for such meetings, which encompassed Brehm's directive.	The order did not clearly mandate transporting to detention under Brehm's directive.	The language was not sufficiently clear and definite to require detention transport under the meeting clause.
Whether the detention directive can be read as a proper 'meeting' directive under the order	Brehm's directive to bring C.A. to detention constituted a meeting directed by the probation officer.	There was no explicit finding that the detention directive was a 'meeting' within the probation order.	Not clearly so; the directive did not establish a meeting under the order with sufficient notice.

Von Hake v. Thomas, 759 P.2d 1162 (Utah 1988) (knowledge and intent required for civil contempt)
Salt Lake City v. Dormam-Ligh, 912 P.2d 452 (Utah Ct.App.1996) (order must be clear and definite to support contempt)
Foreman v. Foreman, 176 P.2d 144 (Utah 1946) (clear, unambiguous orders required for contempt)
Marsh v. Marsh, 1999 UT App 14 (Utah Ct.App.1999) (trial court's discretion in contempt rulings)
State v. Hurst, 821 P.2d 467 (Utah Ct.App.1991) (requirement to preserve challenges to findings)
Utah Farm Prod. Credit Ass'n v. Labrum, 762 P.2d 1070 (Utah 1988) (examples of clear and definite orders supporting contempt)
Envirotech Corp. v. Callahan, 872 P.2d 487 (Utah Ct.App.1994) (contempt for violating preliminary injunctions)
Kunzler v. O'Dell, 855 P.2d 270 (Utah Ct.App.1993) (contumacious conduct under a court directive)