Keating, J. v. Hammond, M.

CourtSuperior Court of Pennsylvania
DecidedApril 8, 2025
Docket575 WDA 2024
StatusUnpublished

This text of Keating, J. v. Hammond, M. (Keating, J. v. Hammond, M.) 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
Keating, J. v. Hammond, M., (Pa. Ct. App. 2025).

Opinion

J-A02011-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

JUSTINE A. KEATING : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : MICHAEL D. HAMMOND : : Appellant : No. 575 WDA 2024

Appeal from the Order Entered April 11, 2024 In the Court of Common Pleas of Washington County Domestic Relations at No(s): 00352DR2009, PACSES: 248110803

BEFORE: KUNSELMAN, J., MURRAY, J., and BECK, J.

MEMORANDUM BY KUNSELMAN, J.: FILED: April 8, 2025

In this matter, Appellant Michael D. Hammond (Former Husband)

appeals the order issued by the Washington County Court of Common Pleas

holding him in contempt and requiring him to pay $1,000.00 as a purge

condition or be incarcerated for six months, pending payment of the purge.

After review, we affirm.

The trial court summarized the following procedural history:

The underlying procedural history of this matter is extensive, containing multiple files over a fifteen (15) year period.[1] Therefore, only the relevant events attendant to

____________________________________________

1We clarify that we refer to the parties as “Former Husband” and “Former Wife” because we glean from the record that the parties were divorced in approximately March 2010. At that time, the proceedings were bifurcated; a Divorce Decree was entered but the economic issues remained. See Trial (Footnote Continued Next Page) J-A02011-25

the instant Petition for Judicial Contempt are outlined herein. On March 3, 2022, a Temporary Order was entered whereby [Former Husband] was directed to pay $3,441.00 per month in support and arrearages to [Justine A. Keating (Former Wife)].[2], [3] Thereafter, on March 29, 2022, the Honorable Jesse Pettit adopted the March 3, 2022 Temporary Order as a Final Order.

Due to [Former Husband]’s failure to make payments in accordance with the support order, the Washington County Domestic Relations Office filed a Petition for Contempt on November 9, 2022. A hearing on the November 9, 2022 Petition for Contempt was held before Hearing Officer Patrick Smider on December 15, 2022. At the conclusion of the hearing, Hearing Officer Smider found [Former Husband] not to be in contempt of the support order at that time but emphasized that if [Former Husband] continued to fail to make timely support payments, Hearing Officer Smider would reconvene the contempt proceeding.

[Former Husband] only made one support payment following the December 15, 2022 hearing and thus, the contempt proceeding was reconvened on March 15, 2023. Following the hearing, Hearing Officer Smider issued a Contempt Hearing Summary and Recommendation in which he recommended that [Former Husband] be found in contempt and further recommended that [Former Husband] be ordered to pay $10,323.00 as a purge condition on or before March 30, 2023.

Court Order, 3/3/10. The trial court’s March 2010 order also converted the spousal support portion of the support action to alimony pendente lite. Id.

2 Former Husband takes issue with the trial court’s use of the word “support”

rather than “alimony pendente lite” (APL). See Former Husband’s Brief at 29 n. 18. This has no impact on our analysis because, as explained infra, the propriety of the underlying APL obligation is not properly before us in this appeal; our focus is solely on the finding of contempt.

3 We observe that some of the dates the trial court uses are the dates written

on the relevant documents, not the dates they were docketed. This does not impact our analysis.

-2- J-A02011-25

Subsequently thereafter, on April 19, 2023, [Former Husband] filed Exceptions to Hearing Officer Smider’s Contempt Hearing Summary and Recommendation. On July 13, 2023, the Honorable Jesse Pettit entered an order granting four (4) of the Exceptions and denying the remainder. The matter was then remanded back to Hearing Officer Smider to address the four (4) exceptions that had been granted.

Following the remand, Hearing Officer Smider issued a new Contempt Hearing Summary and Recommendation on July 21, 2023, resolving the four (4) granted Exceptions and again recommended that [Former Husband] pay $10,323.00 as a purge condition by August 21, 2023. [Former Husband] did not file Exceptions to the July 21, 2023 Contempt Hearing Summary and Recommendation.

Thereafter, on August 14, 2023, [Former Husband] appealed the Honorable Jesse Pettit’s July 13, 2023 order which granted in-part and denied in-part [Former Husband]’s Exceptions to Hearing Officer Smider’s March 30, 2023 Contempt Hearing Summary and Recommendation. The Superior Court of Pennsylvania, in an order dated October 20, 2023, quashed [Former Husband]’s appeal.[4]

Due to [Former Husband]’s continued failure to make the required support payments, [Former Wife] filed a Petition for Bench Warrant on October 31, 2023. That same day, the Honorable Jesse Pettit denied [Former Wife]’s Petition for Bench Warrant. Thereafter, on December 5, 2023, the Honorable Jesse Pettit issued an order scheduling the instant Judicial Contempt Hearing in this matter. The Judicial Contempt Hearing was held before this [c]ourt on February 16, 2024. Following the hearing, this [c]ourt

4 We add that this Court issued a Rule to Show Cause Order because it was

unclear whether the July 13 order constituted an appealable order. It did not appear that the order imposed sanctions without the need for further court action. Former Husband’s response to the Rule to Show Cause Order failed to establish this Court’s jurisdiction. Thus, this Court quashed the appeal. See Order, 10/20/23.

-3- J-A02011-25

directed both parties to submit briefs, which were timely submitted.

Trial Court Opinion and Order (T.C.O.), 4/11/24, at 1-3 (emphasis in original).

Ultimately, the trial court entered an order consisting of the following

four paragraphs:

1. The [c]ourt adopts Hearing Officer Patrick Smider[’]s Contempt Hearing Summary and Recommendation issued on July 21, 2023 and hereby finds Defendant in civil contempt for his failure to willfully comply with the support order entered in this matter.

2. Defendant is directed to pay the lump sum of $1,000.00 to Domestic Relations by April 25, 2024 as a purge of this contempt or be incarcerated for a period of six (6) months pending payment of the purge. If Defendant fails to make the payment by April 25, 2024, a bench warrant shall be issued.

3. The parties shall appear for the previously scheduled APL Modification/Termination Hearing on June 24, 2024. Until said hearing and the issuance of an order granting or denying the modification/termination, Defendant shall pay the ongoing court-ordered support in the amount of $1,000.00 per month, commencing on May 1, 2024.

4. Plaintiff’s Motion for Counsel Fees is preserved for the proceeding before Hearing Officer Patrick Smider on June 24, 2024.

Id. at 8.

Former Husband timely filed this appeal. He raises the following six

issues for our review, which we reorder for ease of disposition:

1. Whether [Former Husband]’s fourteen-year APL obligation is legally proper or equitable given [Former Wife]’s failure to prosecute her related divorce proceedings at Docket 2009-3638 for over twelve years.

-4- J-A02011-25

2. Whether the lower court order of March 29, 2022, confirming the underlying alimony pendente lite obligation giving rise to these contempt proceedings was improvidently granted or without legal basis.

3.

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Keating, J. v. Hammond, M., Counsel Stack Legal Research, https://law.counselstack.com/opinion/keating-j-v-hammond-m-pasuperct-2025.