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Banks v. Wells

Supreme Court of Georgia
Jun 25, 1986
344 S.E.2d 652 (Ga. 1986)

Summary

distinguishing civil and criminal contempt

Summary of this case from In re Rollins

Opinion

43299.

DECIDED JUNE 25, 1986. RECONSIDERATION DENIED JULY 16, 1986.

Contempt. Decatur Superior Court. Before Judge Cato.

Black Black, Eugene C. Black, Jr., for appellant. Ralph C. Smith, Jr., for appellee.


Wells brought a contempt action against his former wife for failure to pay to him a sum of approximately $5,000, pursuant to a divorce decree. The trial court found Mrs. Banks in contempt of court and ordered her incarcerated, allowing her until 5:00 p. m. of that day to purge herself by paying the sum. At around 4:30 p. m. that afternoon, she filed a petition for bankruptcy, seeking a discharge of the debt. The bankruptcy court adjudicated the debt dischargeable as a property settlement. On rehearing, the trial court held that the contempt order remained in effect. We granted Banks' discretionary appeal to determine whether the trial court erred in holding her in contempt for a debt which later was adjudicated to be dischargeable in bankruptcy.

1. Banks contends that the trial court is enjoined from enforcing its contempt order because of the automatic stay provisions of the Federal Bankruptcy Act, 11 U.S.C. § 362. In this case, because the dischargeability of the debt was determined by the bankruptcy court, that issue is now res judicata. Manuel v. Manuel, 239 Ga. 685, 686 ( 238 S.E.2d 328) (1977). The debt is scheduled in Banks' bankruptcy action, and may not be collected through the state's judicial system.

2. The contempt order conditioned Banks' punishment upon repayment of the debt. This we have defined as "civil contempt," whose purpose is to enforce compliance with specific directives. Ensley v. Ensley, 239 Ga. 860, 861-2 ( 238 S.E.2d 920) (1977). The debt having been discharged, civil contempt cannot lie, and the order of the trial court must be vacated.

3. This disposition does not preclude, however, a consideration by the trial court of criminal contempt proceedings to determine whether Banks wilfully refused to obey the prior decree (as well as two prior orders enjoining her from disposing of specific funds within her control which would have satisfied the divorce debt). Criminal contempt, however, requires unconditional imprisonment for a specified length of time, or a fine, or both, Ensley, supra, 239 Ga. at 861-2, and is subject, of course, to other limitations. See Floyd v. Floyd, 247 Ga. 551 ( 277 S.E.2d 658) (1981); In re Bergin, 255 Ga. 429 ( 341 S.E.2d 8) (1986).

Judgment reversed. All the Justices concur.


DECIDED JUNE 25, 1986 — RECONSIDERATION DENIED JULY 16, 1986.


Summaries of

Banks v. Wells

Supreme Court of Georgia
Jun 25, 1986
344 S.E.2d 652 (Ga. 1986)

distinguishing civil and criminal contempt

Summary of this case from In re Rollins

In Banks v. Wells, 256 Ga. 164 (344 S.E.2d 652) (1986), we reviewed the distinctions between civil and criminal contempt and reversed a judgment for civil contempt under facts similar to those in this case.

Summary of this case from Ward v. Ward
Case details for

Banks v. Wells

Case Details

Full title:BANKS v. WELLS

Court:Supreme Court of Georgia

Date published: Jun 25, 1986

Citations

344 S.E.2d 652 (Ga. 1986)
344 S.E.2d 652

Citing Cases

Ward v. Ward

1. In Banks v. Wells, 256 Ga. 164 ( 344 S.E.2d 652) (1986), we reviewed the distinctions between civil and…

In re Rollins

Similarly, as recognized in Bible, 110 B.R. at 1005-06, although a court may impose imprisonment for…