Where a parent is charged with contempt for failure to turn a child over to the other parent for visitation or custody, the conduct occurs outside of the court’s presence and must be construed as indirect contempt and thus proof of facts of which the court cannot take judicial notice must be presented in order for the court to make a finding of contempt. Pryweller v. Pryweller.
Change of custody is an improper remedy to punish a custodial parent’s contumacious interference with visitation rights. In re Fox.
In contempt proceedings involving visitation abuse issues, the importance of the children’s best interests must not be lost. Pryweller v. Pryweller.
Where matters closely related to the issue of visitation are pending, petitioners petition for custody, and respondent’s petition to modify the judgment of dissolution with respect to visitation and relocation, the appealed visitation order was not a final order from which an appeal would lie. In re Bresnahan.