Treme v. Adams, 59 So. 3d 1278

Dr. Elizabeth Adams obtained a contempt judgment against Warren G. Treme for back child support arrears totaling approximately $8,571.25, with regular payments set at $1,043.25 due on the 1st and 15th of each month.
Dr. Adams filed a Rule for Contempt on November 12, 2009, seeking enforcement of the support obligation and related arrears.
At the March 5, 2010 hearing, evidence showed multiple prior contempt rulings (December 2008 and September 2009) and delayed or late payments by Treme, with varying purge payments thereafter.
Dr. Adams testified she incurred $4,026 in attorney’s fees to enforce the support order, claiming funds were not tendered directly to her as required.
The trial court found Treme in contempt, awarded Dr. Adams $2,000 in attorney’s fees and $245 in costs, and sentenced Treme to 90 days in jail (suspended) for missing a payment and to pay the March 1, 2010 payment by March 12, 2010.
On April 14, 2010, Treme moved for de novo appeal challenging the fee award as excessive and challenging the use of redacted bills at trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Attorney’s fees amount on contempt	Adams argues total fees were $4,026; Treme argues $2,000 suffices.	Treme contends the trial court did not justify full costs and fees as related to contempt.	Amend to $4,026; full fee award proper.
Use of unredacted bills for cross-examination	Treme sought unredacted bills to cross-examine Adams on fees.	Redacted bills already limited sensitive information; no prejudice shown.	No error; argument lacks merit.
Frivolous appeal sanctions	Adams sought sanctions against a frivolous appeal.	Treme's appeal was frivolous or lacking substantial question.	No damages for frivolous appeal awarded.

Moises v. Moises, 710 So.2d 1191 (La.App. 5 Cir. 1998) (attorney’s fees may be awarded for enforcing support obligations)
Straughter v. Hodnett, 975 So.2d 81 (La.App. 2 Cir. 2008) (frivolous appeal damages are strictly construed)