Brocker v. Brocker

How later courts describe this case

• "[A] Court can for present or past acts of misbehavior amounting to civil contempt impose an unconditional compensatory fine"
• where the act of contempt complained of is a refusal to do some act ordered primarily for the benefit of a private party, proceedings to enforce compliance with a decree of court are civil in nature
• a court may, in a proceeding for civil contempt, impose the remedial punishment of a fine payable to an aggrieved litigant as compensation for the special damage he or she may have sustained by reason of the contumacious conduct of the offender