D.  Remedial Sanction Findings


In re Marriage of Cyr, 186 P.3d 88 (Colo. App. 2008)
C.R.C.P. 107(e)

The court may fine or imprison a person to compel performance of a court order. The court must specifically describe the means the person may use to purge the contempt and the sanctions that will be imposed until the contempt is purged. The court must find:
  • The person did not comply with a lawful order of the court;
  • The person knew of the order; and
  • The person has the present ability to comply with the order.

The court may combine punitive and remedial sanctions.


In re Marriage of Cyr, 186 P.3d 88 (Colo. App. 2008)
Proof of willfulness is not required before a court may impose remedial sanctions.