Tasha Michelle Fox v. William Jeremiah Fox, 223 So. 3d 192

Parties: Tasha Michelle Fox (appellant) and William Jeremiah Fox (appellee); they share a nine-year-old son.
Chancery court previously granted William unsupervised visitation under an April 2015 order.
Tasha refused to comply with the visitation order; William filed for contempt (alleging civil contempt).
Chancery court denied Tasha’s Rule 60(b) motion seeking to set aside the visitation order, and found her in both civil and criminal contempt, sentencing her to three days imprisonment (suspended on condition she surrender the child for a two-week visit).
On appeal, William did not file an appellee’s brief. Tasha argued the visitation order should be set aside due to the child’s fragile emotional condition and because William failed to complete an alcohol/drug assessment as a condition of unsupervised visits.
The Court of Appeals affirmed denial of Rule 60(b) relief but vacated the criminal contempt finding because Tasha was not afforded required procedural protections for criminal contempt; civil contempt was not disturbed.

Issue	Plaintiff's Argument (Tasha)	Defendant's Argument (William)	Held
Whether the chancery court erred in denying Rule 60(b) relief to set aside the visitation order	The visitation order should be set aside based on the child’s fragile emotional condition and because William failed to complete a required alcohol/drug assessment	Appellee did not file a brief; court considered record and appellant’s briefing	Denial of Rule 60(b) relief affirmed — appellant’s arguments were cursory and unaccompanied by legal authority; waiver and no reversible error shown
Whether the chancery court properly found Tasha in criminal contempt for refusing visitation	Contempt finding improper given procedural defects (implicit in appeal)	Chancery court found both civil and criminal contempt and imposed sentence	Criminal contempt vacated because required procedural safeguards for criminal contempt were not provided; civil contempt finding left intact

Rogillio v. Rogillio, 101 So. 3d 150 (Miss. 2012) (failure of appellee to file brief may be treated as confession of error but court will affirm if record shows no error)
Roberts v. Roberts, 110 So. 3d 820 (Miss. Ct. App. 2013) (standards for reviewing appeals where appellee fails to file a brief and when to treat that failure as confession of error)
Pearson v. Pearson, 121 So. 3d 266 (Miss. Ct. App. 2013) (chancellor’s factual findings reviewed for manifest error; legal conclusions reviewed de novo)
Bennett v. State, 933 So. 2d 930 (Miss. 2006) (failure to cite relevant authority results in waiver on appeal)
In re McDonald, 98 So. 3d 1040 (Miss. 2012) (procedural protections required to support a criminal contempt conviction)