Pennsylvania Consolidated Statutes

23 Pa. Cons. Stat. § 4345 (2026)

 Contempt for noncompliance with support order.

✓ current as of May 2026
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§ 4345.  Contempt for noncompliance with support order.

(a)  General rule.--A person who willfully fails to comply with any order under this chapter, except an order subject to section 4344 (relating to contempt for failure of obligor to appear), may, as prescribed by general rule, be adjudged in contempt. Contempt shall be punishable by any one or more of the following:

(1)  Imprisonment for a period not to exceed six months.

(2)  A fine not to exceed $1,000.

(3)  Probation for a period not to exceed one year.

(b)  Condition for release.--An order committing a defendant to jail under this section shall specify the condition the fulfillment of which will result in the release of the obligor.

(Oct. 16, 1996, P.L.706, No.124, eff. 60 days)

 

Cross References.  Section 4345 is referred to in sections 4326, 4353 of this title.

Notes of Decisions
Cited in 22 cases (5 in the last 5 years), 1988–2026 · leading case: Childress v. Bogosian, 12 A.3d 448 (Pa. Super. Ct. 2011).
Childress v. Bogosian, 12 A.3d 448 (Pa. Super. Ct. 2011). · cites it 3× “Punishment for contempt in support actions is governed by 23 Pa. C.S. § 4345. Section 4345 provides that (a) General rule.”
Thompson, T. v. Thompson, A., 187 A.3d 259 (Pa. Super. Ct. 2018). · cites it 3× “In addition to our conclusion that the indefinitely suspended sentence is illegal, we further find the February 15, 2017 order incorporating the agreement provided no purge amount and contained no mechanism through which the trial court could consider Appellant's present ability…”
Orfield v. Weindel, 52 A.3d 275 (Pa. Super. Ct. 2012). · cites it 3× “Punishment for contempt in support actions is governed by 23 Pa. C.S. § 4345. Section 4345 provides that (a) General rule.”
Godfrey v. Godfrey, 894 A.2d 776 (Pa. Super. Ct. 2006). · cites it 3× “Although we find Godfrey’s refusal to support his family to be reprehensible conduct, which justified the finding of civil contempt under 23 Pa.Cons.Stat.Ann. § 4345, in accordance with current Pennsylvania law we must vacate in part and remand for further proceedings the…”
Hyle v. Hyle, 868 A.2d 601 (Pa. Super. Ct. 2005). · cites it 2× “Punishment for contempt in support actions is governed by 23 Pa. C.S. § 4345. Section 4345 provides that (a) General rule.”
Yerkes v. Yerkes, 824 A.2d 1169 (Pa. 2003). · cites it 2× “See 23 Pa.C.S. § 4345 (requiring willful failure to comply with support order for contempt adjudication); Pa.”
Sonder v. Sonder, 549 A.2d 155 (Pa. 1988). “2d 616 (1977); 23 Pa.C.S. § 4345. See also: Pa.R.C.P. §§ 1910.”
Sheils v. Bucks Cnty. Dom. Relations Section, 921 F. Supp. 2d 396 (E.D. Pa. 2013). “¶ (b)(ii) (emphasis added) 14 (same as to 23 Pa. Cons. Stat. Ann. § 4345), (b) “reporting any purported delinquencies in plaintiffs support payments and notifying the credit reporting agencies”, id.”
Gardner v. Gardner, 538 A.2d 4 (Pa. 1988). “The Civil Procedural Support Law, 23 Pa.C.S. § 4345 provides: § 4345. Contempt for noncompliance with support order (a) General rule.”
Calloway v. Calloway, 594 A.2d 708 (Pa. Super. Ct. 1991). “Here, the court made findings of fact that during the period in question, appellee was unemployed, or marginally employed, and lacked the ability to pay.”
Thompson v. Thompson Apl of: Clarion Dom. Rel. (Pa. 2020). · cites it 3× “23 Pa.C.S. § 4345. In its ensuing opinion, the trial court initially emphasized that the Pennsylvania Rules of Civil Procedure permit parties to reach an agreement during a conference and to submit that agreement to the court.”
R.S. v. R.W. (Pa. Super. Ct. 2017). · cites it 2× “23 Pa.C.S. § 4345(a). 7 The trial court subsequently stayed the October 19, 2015 Contempt Order pending appeal.”
— 23 Pa. Cons. Stat. § 4345(a) — 7 cases
Thompson, T. v. Thompson, A., 187 A.3d 259 (Pa. Super. Ct. 2018). “In addition to our conclusion that the indefinitely suspended sentence is illegal, we further find the February 15, 2017 order incorporating the agreement provided no purge amount and contained no mechanism through which the trial court could consider Appellant's present ability…”
Thompson v. Thompson Apl of: Clarion Dom. Rel. (Pa. 2020). “23 Pa.C.S. § 4345. In its ensuing opinion, the trial court initially emphasized that the Pennsylvania Rules of Civil Procedure permit parties to reach an agreement during a conference and to submit that agreement to the court.”
Perera, A. v. Perera, A. (Pa. Super. Ct. 2025).
R.S. v. R.W. (Pa. Super. Ct. 2017). “23 Pa.C.S. § 4345(a). 7 The trial court subsequently stayed the October 19, 2015 Contempt Order pending appeal.”
— 23 Pa. Cons. Stat. § 4345(a)(2) — 1 case
Childress v. Bogosian, 12 A.3d 448 (Pa. Super. Ct. 2011). “Punishment for contempt in support actions is governed by 23 Pa. C.S. § 4345. Section 4345 provides that (a) General rule.”
— 23 Pa. Cons. Stat. § 4345(b) — 3 cases
Thompson, T. v. Thompson, A., 187 A.3d 259 (Pa. Super. Ct. 2018). “In addition to our conclusion that the indefinitely suspended sentence is illegal, we further find the February 15, 2017 order incorporating the agreement provided no purge amount and contained no mechanism through which the trial court could consider Appellant's present ability…”
R.S. v. R.W. (Pa. Super. Ct. 2017). “23 Pa.C.S. § 4345(a). 7 The trial court subsequently stayed the October 19, 2015 Contempt Order pending appeal.”
I.D. v. K.O.J. (Pa. Super. Ct. 2020).
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