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Peggy (W) and Louis (H) were married and divorced. W got custody, and eventually, H went to court to get an order establishing visitation rights. H was also delinquent in child support payments and was afforded an opportunity to purge himself of contempt. A month later, H moved for an order finding W in contempt for her failure to abide by the schedule for visitation. That motion was dismissed. H filed again almost two months later, and W was found in contempt and sentenced to five days in jail. W appealed; she could not be found guilty of criminal contempt, and the contempt that was found was only civil.

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