On appeal, we interpret settlement agreements de novo. Scott v. Corcoran, 135 N.E.3d 931, 939 (Ind.Ct.App. 2019) (citing Copple v. Swindle, 112 N.E.3d 205, 210 (Ind.Ct.App. 2018)). "Settlement agreements are contractual in nature and binding on the parties once 'the dissolution court merges and incorporates that agreement into the divorce decree.'"
Copple v. Swindle, 112 N.E.3d 205, 213 (Ind.Ct.App. 2018) (citations omitted); see also City of Gary v. Major, 822 N.E.2d 165, 172 (Ind. 2005) ("The determination of damages in a contempt proceeding is within the trial court's discretion, and we will reverse an award of damages only if there is no evidence to support the award
Thus, Father must establish only prima facie error, or in other words, error that is apparent on its face. See Copple v. Swindle, 112 N.E.3d 205, 209 n.2 (Ind.Ct.App. 2018).
[7] Decisions about child support typically are reviewed for clear error. Copple v. Swindle , 112 N.E.3d 205, 209 (Ind. Ct. App. 2018). But when a trial court's decision on child-support modification is controlled by its interpretation of the parties’ settlement agreement, this Court reviews that decision de novo.
Waiver notwithstanding, "freedom of contract principles that govern property settlements do not apply to child support and child custody because of the 'overriding policy concern [to] protect[] the welfare and interests of children.'" Copple v. Swindle, 112 N.E.3d 205, 211 (Ind.Ct.App. 2018) (quoting Voigt v. Voigt, 670 N.E.2d 1271, 1278 n.10 (Ind. 1996)). Even if the rules of contract interpretation were applicable, the plain language of the settlement agreement would not work in Mother's favor, as it requires each party to follow Gottlieb's recommendations "unless that Party can demonstrate that said recommendation is unreasonable."
[4] Travis argues that the trial court erred in finding him in contempt because the settlement agreement does not preclude him from changing beneficiaries and 4 because federal law gives him an absolute right to do so. "Whether a party is in contempt of court is a matter within the trial court's discretion, and its decision will be reversed only for an abuse of that discretion." Copple v. Swindle, 112 N.E.3d 205, 213 (Ind. Ct. App. 2018). "A court abuses its discretion when its decision is against the logic and effect of the facts and circumstances before the court or is contrary to law."
We interpret settlement agreements under a de novo standard. Copple v. Swindle , 112 N.E.3d 205, 210 (Ind. Ct. App. 2018). Settlement agreements are contractual in nature and binding on the parties once "the dissolution court merges and incorporates that agreement into the divorce decree."