Pennsylvania Consolidated Statutes

23 Pa. Cons. Stat. § 6114 (2026)

Contempt for violation of order or agreement.

✓ current as of May 2026

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§ 6114. Contempt for violation of order or agreement.

(a) General rule.--Where the police, sheriff or the plaintiff have filed charges of indirect criminal contempt against a defendant for violation of a protection order issued under this chapter, a foreign protection order or a court-approved consent agreement, the court may hold the defendant in indirect criminal contempt and punish the defendant in accordance with law.

(a.1) Jurisdiction.--A court shall have jurisdiction over indirect criminal contempt charges for violation of a protection order issued pursuant to this chapter in the county where the violation occurred and in the county where the protection order was granted. A court shall have jurisdiction over indirect criminal contempt charges for violation of a foreign protection order in the county where the violation occurred.

(a.2) Minor defendant.--Any defendant who is a minor and who is charged with indirect criminal contempt for allegedly violating a protection from abuse order shall be considered to have committed an alleged delinquent act as that term is defined in 42 Pa.C.S. § 6302 (relating to definitions) and shall be treated as provided in 42 Pa.C.S. Ch. 63 (relating to juvenile matters).

(b) Trial and punishment.--

(1) A sentence for contempt under this chapter may include:

(i) (A) a fine of not less than $300 nor more than $1,000 and imprisonment up to six months; or

(B) a fine of not less than $300 nor more than $1,000 and supervised probation not to exceed six months; and

(ii) an order for other relief set forth in this chapter.

(2) All money received under this section shall be distributed in the following order of priority:

(i) $100 shall be forwarded to the Commonwealth and shall be appropriated to the Pennsylvania State Police to establish and maintain the Statewide registry of protection orders provided for in section 6105 (relating to responsibilities of law enforcement agencies).

(ii) $100 shall be retained by the county and shall be used to carry out the provisions of this chapter as follows:

(A) $50 shall be used by the sheriff.

(B) $50 shall be used by the court.

(iii) $100 shall be forwarded to the Department of Public Welfare for use for victims of domestic violence in accordance with the provisions of section 2333 of the act of April 9, 1929 (P.L.177, No.175), known as The Administrative Code of 1929.

(iv) Any additional money shall be forwarded to the Commonwealth and shall be used by the Pennsylvania State Police to establish and maintain the Statewide registry of protection orders provided for in section 6105.

(3) The defendant shall not have a right to a jury trial on a charge of indirect criminal contempt. However, the defendant shall be entitled to counsel.

(4) Upon conviction for indirect criminal contempt and at the request of the plaintiff, the court shall also grant an extension of the protection order for an additional term.

(5) Upon conviction for indirect criminal contempt, the court shall notify the sheriff of the jurisdiction which issued the protection order of the conviction.

(6) The minimum fine required by subsection (b)(1) allocated pursuant to subsection (b)(2)(i) and (iii) shall be used to supplement and not to supplant any other source of funds received for the purpose of carrying out the provisions of this chapter.

(c) Notification upon release.--The appropriate releasing authority or other official as designated by local rule shall use all reasonable means to notify the victim sufficiently in advance of the release of the offender from any incarceration imposed under subsection (b). Notification shall be required for work release, furlough, medical leave, community service, discharge, escape and recapture. Notification shall include the terms and conditions imposed on any temporary release from custody. The plaintiff must keep the appropriate releasing authority or other official as designated by local rule advised of contact information; failure to do so will constitute waiver of any right to notification under this section.

(d) Multiple remedies.--Disposition of a charge of indirect criminal contempt shall not preclude the prosecution of other criminal charges associated with the incident giving rise to the contempt, nor shall disposition of other criminal charges preclude prosecution of indirect criminal contempt associated with the criminal conduct giving rise to the charges.

(Oct. 6, 1994, P.L.574, No.85, eff. 60 days; Mar. 24, 1998, P.L.204, No.36, eff. 60 days; June 22, 2001, P.L.576, No.39, eff. 60 days; Nov. 10, 2005, P.L.335, No.66, eff. 180 days)

References in Text. The Department of Public Welfare, referred to in this section, was redesignated as the Department of Human Services by Act 132 of 2014.

Cross References. Section 6114 is referred to in sections 5329, 6108 of this title; sections 4136, 4137 of Title 42 (Judiciary and Judicial Procedure).

Notes of Decisions

Cited in 101 cases (45 in the last 5 years), 1992–2026 · leading case: Commonwealth v. Baker, 766 A.2d 328 (Pa. 2001).

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Commonwealth v. Baker, 766 A.2d 328 (Pa. 2001). · cites it 4× “See 23 Pa.C.S. § 6114(b). The trial court found that N.”

Com. v. Wilson, E., 227 A.3d 928 (Pa. Super. Ct. 2020). · cites it 2× “23 Pa.C.S. § 6114(a). This Court has described the elements required for a finding of ICC as follows.”

Trout v. Strube, 97 A.3d 387 (Pa. Super. Ct. 2014). · cites it 4× “23 Pa.C.S. § 6114. Our interpretation of subsection (b)(4) is aided by the section’s procedural history.”

Commonwealth v. Lambert, 147 A.3d 1221 (Pa. Super. Ct. 2016). “23 Pa.C.S. § 6114. 2 . Plaintiff provided unrebutted testimony that the post containing Appellant’s use of the pet name "Sunshine” is not among the October 27, 2015, series of posts appearing in the Commonwealth’s Exhibit 1, but appears, instead, in a subsequent post made by…”

Commonwealth v. Moore, 978 A.2d 988 (Pa. Super. Ct. 2009). · cites it 2× “Pursuant to 23 Pa.C.S. § 6114, this Lower Court found [Appellant] guilty of Indirect Criminal Contempt at all three docket numbers, and [Appellant] was sentenced to serve six months of incarceration at each docket number.”

Commonwealth v. Majeed, 694 A.2d 336 (Pa. 1997). · cites it 3× “While indirect criminal contempt is the appropriate sanction for a violation of a PFA Order, 23 Pa.C.S. § 6114, allowing Appellant to escape liability for burglary would circumvent the purposes of the PFA Order.”

Commonwealth v. Walsh, 36 A.3d 613 (Pa. Super. Ct. 2012). “23 Pa.C.S. § 6114. . See 23 Pa.C.S. §§ 6101-6122.”

Commonwealth v. Felder, 176 A.3d 331 (Pa. Super. Ct. 2017). “…for Violation of. a PFA Order, and, thus, we affirm the judgment of sentence. Judgment of Sentence affirmed. . 23 Pa.C.S. § 6114.”

Ashish Sunuwar v. Attorney Gen. United States, 989 F.3d 239 (3rd Cir. 2021). “Sunuwar later pleaded guilty to contempt under 23 Pa. Cons. Stat. § 6114 (a) for disobeying the protection order.”

State v. Ramos, 2013 NMSC 031 (N.M. 2013). · cites it 2× “720 (4) (2012); 23 Pa. Cons. Stat. Ann. § 6114 (2006); R.”

Commonwealth v. Nelson, 690 A.2d 728 (Pa. Super. Ct. 1997). “” With respect to enforceability, 23 Pa.C.S. § 6114(a) provides that “[wjhere the police or the plaintiff have filed charges of indirect criminal contempt against a defendant for violation of a protection order issued under this chapter or a court-approved consent agreement, the…”

Com. v. Wilson, E., 2020 Pa. Super. 18 (Pa. Super. Ct. 2020). · cites it 2× “23 Pa.C.S. § 6114(a). This Court has described the elements required for a finding of ICC as follows.”

Show all 101 citing cases →

— 23 Pa. Cons. Stat. § 6114(a) — 43 cases

Com. v. Wilson, E., 227 A.3d 928 (Pa. Super. Ct. 2020). “23 Pa.C.S. § 6114(a). This Court has described the elements required for a finding of ICC as follows.”

Com. v. Wilson, E., 2020 Pa. Super. 18 (Pa. Super. Ct. 2020). “23 Pa.C.S. § 6114(a). This Court has described the elements required for a finding of ICC as follows.”

Rivera, M. v. Gutierrez, L. (Pa. Super. Ct. 2022).

Shulla, M. v. Knorr, C., Jr. (Pa. Super. Ct. 2022).

— 23 Pa. Cons. Stat. § 6114(b) — 5 cases

Commonwealth v. Baker, 766 A.2d 328 (Pa. 2001). “See 23 Pa.C.S. § 6114(b). The trial court found that N.”

Com. v. Velez-Diaz, L. (Pa. Super. Ct. 2016).

Com. v. Pedrick, A. (Pa. Super. Ct. 2017).

Mangan, S. v. Reznickcheck, J. (Pa. Super. Ct. 2019).

Miller v. Walker, 24 Pa. D. & C.4th 259 (1995).

— 23 Pa. Cons. Stat. § 6114(b)(1) — 4 cases

Britton, K. v. Maksimov, A. (Pa. Super. Ct. 2017).

Com. v. Bonafide, N. (Pa. Super. Ct. 2021).

A.J.I. v. L.P. (Pa. Super. Ct. 2021).

Com. v. Mallory, M. (Pa. Super. Ct. 2026).

— 23 Pa. Cons. Stat. § 6114(b)(1)(B) — 1 case

Com. v. Khare, N. (Pa. Super. Ct. 2024).

— 23 Pa. Cons. Stat. § 6114(b)(1)(i) — 1 case

Donadio, L. v. Friend, W. (Pa. Super. Ct. 2026).

— 23 Pa. Cons. Stat. § 6114(b)(1)(i)(A) — 1 case

Com. v. Curry, K. (Pa. Super. Ct. 2021).

— 23 Pa. Cons. Stat. § 6114(b)(3) — 12 cases

Com. v. Wilson, E., 227 A.3d 928 (Pa. Super. Ct. 2020). “23 Pa.C.S. § 6114(a). This Court has described the elements required for a finding of ICC as follows.”

Com. v. Wilson, E., 2020 Pa. Super. 18 (Pa. Super. Ct. 2020). “23 Pa.C.S. § 6114(a). This Court has described the elements required for a finding of ICC as follows.”

Britton, K. v. Maksimov, A. (Pa. Super. Ct. 2017).

Com. v. Akins, D. (Pa. Super. Ct. 2019).

Com. v. Wilson, E. (Pa. Super. Ct. 2019).

— 23 Pa. Cons. Stat. § 6114(b)(4) — 4 cases

Trout v. Strube, 97 A.3d 387 (Pa. Super. Ct. 2014). “23 Pa.C.S. § 6114. Our interpretation of subsection (b)(4) is aided by the section’s procedural history.”

R.L.M. v. E.M. (Pa. Super. Ct. 2017).

L.C. v. Lewis, W. (Pa. Super. Ct. 2020).

A.J.I. v. L.P. (Pa. Super. Ct. 2021).

— 23 Pa. Cons. Stat. § 6114(c) — 1 case

Rowles v. Rowles, 26 Pa. D. & C.4th 264 (1994).

— 23 Pa. Cons. Stat. § 6114(d) — 1 case

Rowles v. Rowles, 26 Pa. D. & C.4th 264 (1994).

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