Williams v. ChaneyÂ, 250 N.C. App. 476

Williams and Chaney have litigated child custody for over a decade; Chaney has primary legal and physical custody and Williams has visitation.
A May 15, 2015 order modified Williams’s visitation and enjoined her from intimidating the child or making derogatory statements about the child or child’s family members.
On December 3, 2015 the trial court found Williams in contempt based on a Facebook post on a youth football team page and ordered her to pay attorney’s fees.
Williams appealed the contempt order (filed January 14, 2016); timeliness of appeal raised jurisdictional questions, but the Court of Appeals granted certiorari to reach the merits.
The Court of Appeals reviewed whether the May 2015 order clearly prohibited the Facebook post and whether Williams’s violation was willful, and whether attorney’s fees were properly awarded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Williams was properly held in contempt for Facebook comments	Williams argued the May 2015 order did not clearly prohibit her Facebook post and thus she lacked willful noncompliance	Chaney argued the May 2015 order barred derogatory statements about the child/family, including on social media	Reversed: order ambiguous as to social-media communications; willfulness (knowledge + stubborn resistance) not proved, so contempt improper
Whether attorney’s fees could be awarded in the contempt order	Williams contended fees were not supported by statutory findings required under § 50‑13.6	Chaney relied on fees as part of enforcing custody/support orders	Reversed: trial court failed to make statutory findings (good faith, insufficient means, or frivolous action) required to award fees; award erroneous

Dogwood Dev. & Mgmt. Co. v. White Oak Transp. Co., 362 N.C. 191 (failure to timely file notice of appeal mandates dismissal)
Anderson v. Worthington, 238 N.C. 577 (timely petition to appeal as indigent is mandatory)
Luther v. Seawell, 191 N.C. App. 139 (granting certiorari under N.C. R. App. P. 21)
Clark v. Clark, 294 N.C. 554 (findings of fact in contempt proceedings are conclusive if supported by competent evidence)
Mauney v. Mauney, 268 N.C. 254 (contempt requires willful noncompliance: knowledge and stubborn resistance)
Blevins v. Welch, 137 N.C. App. 98 (ambiguous prior order defeats finding of knowledge for contempt)
Bowman v. Comfort Chair Co., 271 N.C. 702 (general rule that counsel fees are not allowed absent statutory authority)
Wiggins v. Bright, 198 N.C. App. 692 (statutory prerequisites for awarding attorney’s fees in custody/support proceedings)