Is There a Statute of Limitations for Filing for Contempt in North Carolina? | The Law Corner | Raleigh, NC
Precedent Case: State Board of Examiners of Plumbing Heating and Fire Sprinkler Contractors v. Hudson, N.C. App., S.E.2d (May 21, 2025).
The trial court erred when it signed and filed an order finding defendant in civil contempt after the defendant paid the entire amount of purge announced by the trial court at the conclusion of the contempt hearing. A respondent must continue to be in civil contempt at the time the trial court enters an order finding respondent in contempt.
The trial court conducted a hearing on plaintiff’s motion for civil contempt and at the end of the hearing, announced that father was in civil contempt for his failure to pay child support and medical expenses. The court also announced that father could purge contempt by paying $3,348.06. The father was immediately incarcerated. He executed a cash bond for the full amount of the purge and was released from incarceration. Approximately 19 days later, the trial court entered a written order, concluding father was in civil contempt and finding that he had complied with the purge ordered. The court of appeals vacated the order, concluding that the trial court erred in holding father in civil contempt after he had complied with the child support order.
For civil contempt, a respondent must be in contempt at the time the order is entered, which means when it is reduced to writing, signed by the court, and filed by the clerk of court.




