Van Orden v. Van Orden, 2011 Ohio 2246

Hannah Van Orden and David Van Orden married in 1998; five children were born of the marriage.
Divorce filed in 2006; final hearing in 2007; bankruptcy filed by Appellant in 2007; discharge entered in July 2008.
Divorce decree required Defendant to pay all marital debt and hold Plaintiff harmless therefrom.
Fifth Third Bank and USAA obtained judgments against Plaintiff after the bankruptcy discharge.
Plaintiff filed a contempt motion in March 2009 for Appellant's failure to hold her harmless; a magistrate’s decision found contempt in December 2009; trial court adopted it in June 2010.
Contempt order purportedly required Appellant to pay Plaintiff’s attorney fees and to arrange payment of the judgments within 90 days; no purge opportunity or specific sanction/amount was imposed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the contempt order was final and appealable	Appellant contends the order was final and appealable.	Contempt orders require a purge opportunity and a sanctions/amount determination to be final.	No final appealable order; appeal is dismissed.
Whether the order imposing attorney fees and payment arrangements was appealable	Appellee sought attorney fees and arrangements to satisfy judgments.	No final order amount determined and no purge/sanction finalized.	No final appealable order regarding fees or payment arrangements.

Slone v. Slone, 2002-Ohio-687 (Ohio) (civil contempt requires purge opportunity; appellate review governed by abuse-of-discretion standard)
Boggs v. Boggs, 118 Ohio App.3d 293 (1997) (civil contempt sanctions; standards for final appealable order)
Brown v. Executive 200, Inc., 64 Ohio St.2d 250 (1980) (civil contempt framework and sanctions)
In re Purola, 73 Ohio App.3d 306 (1991) (purge and finality principles in contempt)