In this earlier post, my current colleague Danny Spiegle (who was an NC Assistant Appellate Defender at the time the post was published), analyzed the law of civil contempt and concluded that “springing orders for arrest upon future nonpayment of purge payments in child support civil contempt proceeding without contemporaneous inquiry into ability to pay” are unlawful. https://civil.sog.unc.edu/civil-contempt-and-springing-orders-for-arrest/  In an opinion issued June 18, 2025, the NC Court of Appeals agreed with that assessment. Collins v. Holley, NC App. (June 18, 2025).