People v. Batts

In a criminal case, the defendant filed a petition for rule to show cause against two doctors who were officials of the Department of Human Services for failing to transfer defendant to a department facility for fitness restoration treatment in violated of the trial court’s order. The circuit court issued the rule to show cause, found the doctors in indirect civil contempt of court, and imposed a monetary sanction for every day that passed without defendant being transferred to a facility. After the transfer was completed and the monetary sanction established, the department and the doctors appealed. The appellate court vacated the trial court’s contempt order and the sanction imposed, finding that the evidence was insufficient to support a finding that the doctors willfully or contumaciously violated the court’s order. (HOLDRIDGE and ANDERSON, concurring)