Background
Anthony T. Head and Chinequa N. Taylor Head divorced in 2023. During the divorce proceedings, the domestic-relations court had entered a temporary restraining order that prohibited, among other things, encumbering property and changing insurance beneficiaries. The final divorce decree expressly released all restraining orders and terminated all temporary orders.
In January 2026, Anthony moved to hold Chinequa in contempt. He alleged that she had not paid amounts awarded to him for equity in a Chevrolet Tahoe and reimbursement involving a Navy Federal Credit Union account. He also alleged that she had violated the temporary restraining order during the divorce proceedings by placing the parties’ mortgage into forbearance, removing him from health insurance, and withholding financial information. The trial court found Chinequa in contempt for failing to pay the amounts required by the divorce decree but rejected the claims based on the former temporary order.
The Court’s Holding
The Second District affirmed. It held that Anthony received notice and an opportunity to be heard at the contempt hearing. Although he argued that the trial court improperly prevented him from presenting evidence about the alleged temporary-order violations, he did not object or proffer the purportedly excluded evidence. In any event, that evidence could not have changed the result.
The temporary restraining order had merged into the final divorce decree and was expressly terminated when the decree was entered. Because the order was no longer enforceable when Anthony filed his contempt motion, the trial court could not hold Chinequa in contempt for alleged violations of it, and evidence concerning those alleged violations was irrelevant.
The appellate court also declined to review Anthony’s argument that the February 25, 2026 amended divorce decree failed to comply with an earlier appellate mandate. His notice of appeal designated only the separate March 23 contempt judgment, so the court lacked jurisdiction to review the amended decree.
Key Takeaways
- Temporary domestic-relations orders generally merge into the final decree and cannot later support contempt unless preserved in a separate judgment or specifically incorporated into the decree.
- A party challenging the exclusion of evidence must ordinarily object and make the substance of the evidence known through a proffer or the surrounding context.
- An appellate court lacks jurisdiction to review a separate final order that the notice of appeal does not designate.
Why It Matters
The decision underscores that alleged violations of temporary divorce orders should be raised before the final decree terminates or supersedes those orders. Once a temporary order has merged into a decree and been expressly released, a later contempt motion cannot revive it.
It also highlights the importance of identifying every challenged final order in the notice of appeal. Appealing a contempt judgment does not automatically place a separate amended divorce decree before the appellate court.