Mark S. LaFrance

The appellant appealed an order finding him in contempt for failing to comply with interim child support, spousal support, and financial disclosure orders in a divorce proceeding.

The motions judge had ordered a warrant of committal for seven days and struck his pleadings.

The Court of Appeal dismissed the appeal, holding that while payment orders cannot be enforced by contempt proceedings under the Family Law Rules, the committal was properly based on the appellant's flagrant failure to comply with production orders.

The Court also found no error in the motions judge's exercise of discretion to strike the pleadings given the history of non-compliance.