Albert Whitney Coburn v. Lara Brooke Seefeldt
1. Whether the Fourteenth Amendment permits a state court to impose civil contempt for
nonpayment without making the ability-to-pay findings required by Turner v. Rogers and
Bearden v. Georgia, even when the court openly admits it lacks the financial information
necessary to determine ability to comply.
2. Whether the Consumer Credit Protection Act (CCPA), 15 U.S.C. § 1673, preempts a state
court contempt order enforcing an obligation that requires withholding far in excess of
federal garnishment limits, despite Congress 's express prohibition on any court making or
enforcing an order that violates those limits.
3. Whether a state court may impose contempt sanctions for nonpayment of private school
tuition after the State 's Title IV-D agency has refused to enforce that obligation as child
support under federal law, and where the state court simultaneously classified the same
obligation as both "not child support " (to avoid federal protections) and "child support "
(to impose contempt).
4. Whether a state court may compel a parent to fund private school tuition for a disabled
child —at a school not bound by IDEA —without evaluating educational necessity,
appropriateness, efficacy, or the child 's right to a Free Appropriate Public Education
under federal law.
Whether the Fourteenth Amendment permits a state court to impose civil contempt for nonpayment without making ability-to-pay findings required by Turner v. Rogers and Bearden v. Georgia, and whether the Consumer Credit Protection Act preempts state court contempt orders enforcing obligations requiring withholding in excess of federal garnishment limits, and whether a state court may impose contempt sanctions for nonpayment of private school tuition after a state Title IV-D agency has refused to enforce that obligation as child support, and whether a state court may compel a parent to fund private school tuition for a disabled child without evaluating educational necessity under federal law