This issue was addressed recently by the North Carolina Court of Appeals in the matter of Bridges v Bridges filed on May 21, 2025.  A brief summary of the facts are as follows:

In June of 2023 Plaintiff filed a Motion for Civil Contempt alleging non payment of court ordered child support, medical expenses and attorney fees. On September 5, 2023 the Motion was heard and the Judge ruled from the bench finding Defendant in civil contempt and ordered him to pay about $3,300 to purge himself of contempt.

On September 10, 2023 Defendant posted the entire amount of money required to purge himself of contempt. On September 29, 2023 the Court's written order is entered in accord with the terms of the oral ruling September 5, 2023.  On 29 September 2023, the trial court filed its written order finding Defendant in contempt and that Defendant had purged himself of that contempt.

The sole issue on appeal is whether the trial court erred by holding Defendant in contempt after he had paid the entirety of the purge amount.

The court of appeals reasoned otherwise.  In relying on Ruth v. Ruth, 158 N.C. App. 123, 126, 579 S.E.2d 909, 912 (2003) (alterations in original) (quoting Brower v. Brower, 70 N.C. App. 131, 133, 318 S.E.2d 542, 544 (1984)), the court stated that a district court does not have authority to find a person in contempt once they have purged, regardless of the timing of the filing of the Motion.  Further the Court of Appeals noted that N.C.R. Civ. P., Rule 58  "[A] judgment is entered when it is reduced to writing, signed by the judge, and filed with the clerk of court."

Needless to say the order of contempt was vacated.  But how fair is this policy to the non offending party?  Will they always have to wait for an arrearage to accrue, then hire an attorney and file legal paperwork, just to get the opposing party to comply, without any ramifications for non compliance? 

Seems to be a bit backwards.

Guy Vitetta, Charleston SC