Jean, S. v. Morgan, J.

CourtSuperior Court of Pennsylvania
DecidedJanuary 6, 2026
Docket704 MDA 2025
StatusUnpublished

This text of Jean, S. v. Morgan, J. (Jean, S. v. Morgan, J.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jean, S. v. Morgan, J., (Pa. Ct. App. 2026).

Opinion

J-S42002-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

SHANA M. JEAN : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : JONATHAN M. MORGAN : : Appellant : No. 704 MDA 2025

Appeal from the Order Entered May 19, 2025 In the Court of Common Pleas of Lycoming County Civil Division at No(s): 20-DR-00151, CV-2025-00813-CV

BEFORE: OLSON, J., KING, J., and LANE, J.

MEMORANDUM BY OLSON, J.: FILED JANUARY 06, 2026

Appellant, Jonathan M. Morgan (“Father”), appeals pro se from the May

13, 2025 order finding him in contempt of court and, inter alia, remanding

Father to the Lycoming County Prison for a period of seven days. We affirm.

The trial court summarized the relevant factual and procedural history

of this case as follows.

[T]his matter was opened in 2020 when [Mother] filed for child support against [Father] as she had primary custody of their minor child. An initial child support assessment was made against Father [] in August [] 2021. The parties agreed to a 50/50 custody agreement and [Father] filed for support against Mother. In February [] 2021[,] Mother once again received primary custody and the current docket reopened and [Father’s] initial support assessment was reinstated.

On July 6[,] 2022, a hearing officer received testimony regarding Mother’s reopened complaint and assessed [Father’s] support obligation at $433.86 [per month]. In August [] 2022[, Father] filed a petition for modification where he alleged that all of his circumstances were not considered. Between the time J-S42002-25

the current support order was entered and the time [Father] filed his modification, contempt proceedings were initiated against [Father]. On August 30[,] 2022[,] the contempt hearing was rescheduled [to allow Father] to present evidence of his various medical diagnosis.

The contempt proceedings were continued ultimately to October 6[,] 2023. Between August 30[,] 2022 and the rescheduled hearing[,] various other contempt petitions were filed by the Lycoming County Domestic Relations Office (DRO). [Father] was found in contempt on all of the other petitions and managed to meet the purge amount for each finding prior to his report date. On October 6[,] 2023, at the rescheduled contempt hearing[,] the [trial c]ourt declined to find [Father] in contempt in part because he had obtained employment. Following that hearing[, Father] filed another petition for modification on October 17[,] 2023. Said petition was dismissed on November 16[,] 2023 as [Father] failed to present any new information that would warrant a change in his support obligations.

On December 6[,] 2023[,] another contempt petition was filed by Lycoming County DRO. The [trial c]ourt declined to find [Father] in contempt on January 12[,] 2024[,] finding that [Father’s] contempt was not willful[ but the] result of his mental health struggles. [Father] filed [another petition to modify] modification for support on May 31, 2024. The modification [petition] was scheduled for a hearing on July 12[,] 2024, but was continued because [Father] alleged once again that he was medically disabled, but at the time of the hearing he failed to provide a Physician Verification Form and failed to present any evidence from a doctor. Said hearing was rescheduled for November 22[,] 2024. At the time of the hearing[,] Dr. Steven Barrows testified that, although [Father] does deal with depression, anxiety, and emotional control, [Father] should not be considered disabled and that there are no limitations on [Father’s] ability to earn an equivalent income as one with wage attachable employment. As a result, the petition was dismissed. Exceptions were then filed and the case was remanded to the hearing officer solely for the hearing officer to hear testimony regarding an additional child that [Father] cared for full-time that was not previously considered.

While [Father’s] motion was pending[,] another contempt petition was filed by Lycoming County DRO and was heard on January 3[,] 2025. The [trial c]ourt found [Father] in contempt

-2- J-S42002-25

with a sentence of two months with a purge payment of $3,750.00. [Father] then filed a motion for reconsideration that was granted and heard on February 18[,] 2025. As a result of that hearing[,] the purge conditions were modified. [Father] was [] required to produce 20 signed agreements/contracts with various customers for his business. Additionally, he was required to meet with a representative from PA CareerLink and explore the self-employment options within 10 days of the order.

[Father’s] deadline to complete his purge requirements was March 31[,] 2025. On March 21[,] 2025[, Father] filed a motion to stay enforcement of the contempt pending appeal and a motion to extend the appeal window of the February 18th order. Those petitions were denied [on March 24, 2025 and March 25, 2025]. Following [the aforementioned] orders, a bench warrant was issued for [Father’s] failure to comply with the purge requirements of the February 18[, 2025] order. [Father] was arrested and the bench warrant was vacated on April 4[,] 2025 at which time a contempt hearing was he[ld] for his failure to comply with the order. He was sentenced to a period of three-month’s incarceration with a purge payment of $500[.00. Father] then filed a number of petitions regarding the April 4 th contempt order[, again] asking for reconsideration of that order. Those petitions were [ultimately denied on May 1, 2025 and May 7, 2025].

A subsequent bench warrant was issued on May 5[,] 2025 for [Father’s] failure to comply with the purge requirements of the April 4th order. A hearing was held on May 13[,] 2025[,] where the [trial c]ourt [ordered Father to serve] seven days[’] incarceration for indirect criminal contempt. Additionally, the [trial c]ourt amended the purge payment for [the] April 4th contempt order to include the child support payment for the month of May[,] making the total purge payment for the April 4th contempt order $907.63. On May 19[,] 2025 the [trial c]ourt signed an order releasing [Father] from prison as his seven[-]day sanction was completed. [This timely appeal followed].

Trial Court Opinion, 7/24/25, at 1-4 (unnecessary capitalization omitted).

Father raised the following issues for our consideration.

-3- J-S42002-25

1. Did the trial court violate [Father’s] due process [rights] by incarcerating [Father] for civil contempt without first conducting a meaningful ability-to-pay hearing and making findings on his present financial resources?

2. Did the trial court err by converting a bench warrant hearing into a contempt proceeding without prior notice and by silencing [Father’s] objections, thereby denying him the opportunity to be heard?

3. Was [Father’s] confinement unlawful under the Fourteenth Amendment where he was held for eight days despite the trial court’s imposition of a seven-day sentence?

4. Did the trial court’s order result in unconstitutional conditions of confinement when [Father] was denied access to prescribed medications during incarceration?

Father’s Brief at 5-6.

On appeal, Father challenges the trial court’s order finding him in

contempt. “The standard of review for an order finding a party in contempt

is an abuse of discretion. Discretion is abused when the course pursued

represents not merely an error of judgment, but where the judgment is

manifestly unreasonable or where the law is not applied.” Commonwealth

v. Diaz, 191 A.3d 850, 864 (Pa. Super. 2018) (citations omitted).

We have carefully reviewed the certified record, the submissions of the

parties, the opinion of the trial court, and the pertinent case law. Based upon

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Related

Cunningham, B. v. Cunningham, A.
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Commonwealth v. Diaz
191 A.3d 850 (Superior Court of Pennsylvania, 2018)

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Bluebook (online)
Jean, S. v. Morgan, J., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jean-s-v-morgan-j-pasuperct-2026.