Louise Gombako-Amos v. Corey Rene Amos

CourtMississippi Supreme Court
DecidedJune 4, 2026
Docket2023-CT-01253-SCT
StatusPublished

This text of Louise Gombako-Amos v. Corey Rene Amos (Louise Gombako-Amos v. Corey Rene Amos) is published on Counsel Stack Legal Research, covering Mississippi Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Louise Gombako-Amos v. Corey Rene Amos, (Mich. 2026).

Opinion

IN THE SUPREME COURT OF MISSISSIPPI

NO. 2023-CT-01253-SCT

LOUISE GOMBAKO-AMOS

v.

COREY RENE AMOS

ON WRIT OF CERTIORARI

DATE OF JUDGMENT: 11/03/2023 TRIAL JUDGE: HON. WAYNE SMITH TRIAL COURT ATTORNEYS: RONALD L. WHITTINGTON WAYNE DOWDY JOHN JAMIL McNEIL COURT FROM WHICH APPEALED: PIKE COUNTY CHANCERY COURT ATTORNEYS FOR APPELLANT: JOHN S. GRANT, IV JARED FRANK EVANS ATTORNEYS FOR APPELLEE: RONALD L. WHITTINGTON EDWIN L. BEAN, JR. NATURE OF THE CASE: CIVIL - DOMESTIC RELATIONS DISPOSITION: REVERSED, RENDERED, AND REMANDED - 06/04/2026 MOTION FOR REHEARING FILED:

EN BANC.

GRIFFIS, JUSTICE, FOR THE COURT:

¶1. In this certiorari case, we must determine whether the chancellor’s finding of civil

contempt and award of attorneys’ fees was proper. Because no clear and convincing

evidence of a willful and deliberate violation of a court order was presented, we reverse the

decisions of the chancery court and the Court of Appeals, we render judgment as to

attorneys’ fees, and we remand the case to the chancery court to determine the appropriate

time and manner for reimbursement. FACTS AND PROCEDURAL HISTORY

¶2. In August 2019, Louise Gombako-Amos and Corey Rene Amos consented to an

irreconcilable-differences divorce and obtained a judgment of divorce. The property

settlement agreement (PSA), which was incorporated into the judgment of divorce, provided

in relevant part that Louise “shall be responsible for the . . . Trustmark National Bank

Judgment” and “shall hold [Corey] harmless from liability thereon.” In February 2021,

Trustmark National Bank began to garnish Louise’s salary every month in order to pay the

Trustmark judgment. From February 2021 to April 2022, Trustmark National Bank

garnished $51,480.34 from Louise’s salary. A total of $50,518.33, however, remained owed

on the Trustmark judgment.

¶3. In March 2022, Corey decided to sell a property in New Orleans that he had received

in the PSA. “Prior to closing, Corey learned [that] the Trustmark judgment had been enrolled

as a lien against the property and that he would be required to pay off the judgment in order

to complete the sale.” Gombako-Amos v. Amos, No. 2023-CA-01253-COA, 2025 WL

1741843, at *1 (Miss. Ct. App. June 24, 2025). “Corey paid the balance of the judgment

($50,518.33) at closing.” Id. It is undisputed that Corey did not discuss with or advise

Louise of the lien nor did Corey advise Louise that he had paid off the Trustmark judgment.1

¶4. Louise was advised by Trustmark National Bank in April 2022 that the Trustmark

judgment had been released. “According to Louise, she ‘didn’t know why’ Trustmark had

released the judgment because she ‘had no idea [Corey] had sold his property.’” Id.

1 “Louise and Corey both testified that they do not communicate well and do not talk much.” Id. n.2.

2 (alteration in original).

¶5. In June 2022, Corey filed a complaint for citation of contempt for Louise’s failure to

pay the Trustmark judgment. In his complaint for contempt, Corey asserted that Louise

“ha[d] wholly ignored and failed and refused to remit to him those monies owed and that said

conduct constitute[d] a willful contemptuous violation of the terms and provisions of the

[PSA].” Corey requested that Louise be held in contempt and that she be ordered to pay the

indebtedness and reimburse him $50,518.33, plus interest and attorneys’ fees.

¶6. After a hearing, the chancellor found Louise had violated the terms of the PSA and

was “in willful contumacious contempt of th[e] [c]ourt.” The chancellor ordered Louise to

pay Corey the lump sum amount of $50,518.32, plus 5 percent interest, within ninety days.

The chancellor also awarded Corey $4,000 in attorneys’ fees to be paid by Louise within

sixty days. Louise timely appealed to this Court, and the case was assigned to the Court of

Appeals.

¶7. The Court of Appeals affirmed the chancellor’s decision, stating:

The PSA required Louise to hold Corey harmless from any liability on the Trustmark judgment. Therefore, Louise was required to reimburse Corey once he had to pay the judgment to obtain a release of Trustmark’s lien on his property. In addition, we cannot say that the chancellor clearly erred or abused his discretion by finding Louise in contempt for failing to comply with the PSA and the divorce decree.

Id. at *4.

¶8. Louise timely filed a petition for writ of certiorari, which we granted. In her petition,

Louise argues that the finding of contempt was improper and that the award of attorneys’ fees

should be set aside.

3 STANDARD OF REVIEW

¶9. “When reviewing a chancellor’s findings, this Court employs a limited standard of

review.” Williams v. Williams, 347 So. 3d 178, 181 (Miss. 2022) (internal quotation marks

omitted) (quoting Miller v. Pannell, 815 So. 2d 1117, 1119 (Miss. 2002)). “The chancellor’s

findings will not be disturbed upon review unless the chancellor was manifestly wrong,

clearly erroneous or applied an incorrect legal standard.” Id. (internal quotation marks

omitted) (quoting Miller, 815 So. 2d at 1119). “The standard of review employed by this

Court for review of a chancellor’s decision is abuse of discretion.” Id. (internal quotation

marks omitted) (quoting Miller, 815 So. 2d at 1119). “[Q]uestions of law are reviewed de

novo.” Id. (alteration in original) (internal quotation marks omitted) (quoting Countrywide

Home Loans, Inc. v. Parker, 975 So. 2d 233, 234 (Miss. 2008)).

¶10. “Contempt is an issue of fact to be decided on a case-by-case basis.” R.K. v. J.K., 946

So. 2d 764, 777 (Miss. 2007) (citing Mizell v. Mizell, 708 So. 2d 55, 64 (Miss. 1998)).

“Normally, the factual findings of the chancellor are affirmed unless manifest error is present

and apparent.” Purvis v. Purvis, 657 So. 2d 794, 797 (Miss. 1994) (citing Caldwell v.

Caldwell, 579 So. 2d 543, 545 (Miss. 1991)).

DISCUSSION

I. Contempt

¶11. Louise argues the finding of contempt was improper “[b]ecause there is no evidence

[she] willfully violated a court order” and “[b]ecause the . . . PSA is silent or ambiguous on

how and when [she] was required to satisfy the Trustmark debt[.]” We agree.

4 A. Louise did not willfully violate the PSA.

¶12. This case involves an issue of civil contempt. “The purpose of civil contempt is to

compel compliance with the court’s orders, admonitions, and instructions, while the purpose

of criminal contempt is to punish.” Corr v. State, 97 So. 3d 1211, 1214 (Miss. 2012)

(internal quotation marks omitted) (quoting Graves v. State, 66 So. 3d 148, 151 (Miss.

2011)). “An adjudication of contempt is a serious matter and must, in the case of civil

contempt, be prove[d] by clear and convincing evidence.” Allred v. Allred, 735 So. 2d 1064,

1067 (Miss. Ct. App. 1999) (citing Masonite Corp. v. Int’l Woodworkers of Am., 206 So.

2d 171, 180 (Miss. 1967)). “To be found in [civil] contempt, a party has to willfully and

deliberately violate a court order.” McKnight v. Jenkins, 155 So. 3d 730, 732 (Miss.

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Louise Gombako-Amos v. Corey Rene Amos, Counsel Stack Legal Research, https://law.counselstack.com/opinion/louise-gombako-amos-v-corey-rene-amos-miss-2026.