Rosser v. Rosser, 2019 UT App 25 (Feb. 14, 2019)

This appeal arose out of a post-divorce contempt proceeding.  The parties’ mediation agreement required appellant to pay 50% of a tax obligation.  Both parties mistakenly believed the other had paid the tax, and the decree of divorce made Wife solely responsible any tax and the recipient of any refund.  The district court found Husband in contempt for being deceitful and failing to make payments under the mediation agreement.  Reversing, the court of appeals clarified that the fraud provision of the contempt statute applies only to fraud committed on the court.  Because Wife had failed to show deceit or a violation of the decree, the contempt order was vacated.