BRYANT v. HOWARD CTY DEPARTMENT OF SOCIAL SERV.

No. 93, September Term, 2004.

874 A.2d 457 (2005)

387 Md. 30

Joseph David BRYANT v. HOWARD COUNTY DEPARTMENT OF SOCIAL SERVICES ex rel. Cassandra COSTLEY.

Court of Appeals of Maryland.

May 12, 2005.


Attorney(s) appearing for the Case

Julia Doyle Bernhardt, Asst. Public Defender (Nancy S. Forster, Public Defender, on brief), for appellant.

Barbara T. Strong, Asst. Atty. Gen. (J. Joseph Curran, Jr., Atty. Gen., on brief), for appellee.

Argued before BELL, C.J., RAKER, WILNER, HARRELL, BATTAGLIA, GREENE and JOHN C. ELDRIDGE (Retired, Specially Assigned), JJ.


WILNER, J.

The ability of a court to enforce child support orders entered by it is often difficult and frustrating. In many cases, the court must invoke, as a last resort, its power to punish a wilfully non-compliant parent for contempt, but when the exercise of that power involves incarceration—deprivation of the parent's liberty—it is subject to certain circumscribing conditions and limitations. In 1997, through the adoption of Maryland Rules 15-201...

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