Trial court erred in holding the defendant in civil contempt for violating a Civil No Contact Order entered pursuant to Chapter 50C where there was no evidence that defendant was violating the order at the time of the civil contempt hearing. Violations of a court order that occurred in the past and that are not continuing at the time of the contempt hearing are punished by criminal contempt rather than civil contempt. 

 A civil no-contact order was entered pursuant to Chapter 50C which prohibited the defendant from being within 100 feet of plaintiff. The trial court found the defendant to be in civil contempt after determining that he violated the order on two occasions by willfully coming too close to plaintiff. Defendant appealed and the court of appeals reversed the order of civil contempt, explaining that because the purpose of civil contempt is to coerce compliance with a court order, the trial court must find that a defendant is violating the order at the time of the hearing. 



Criminal contempt must be used to punish a defendant for past violations of a court order.