In re Marriage of Conners.

2024 CO 44. No. 23SA332. Civil Procedure—Contempt—Indirect Contempt—Service of Process—Direct Service.

June 17, 2024

In this original proceeding, the Supreme Court held that Colorado Rule of Civil Procedure 107, as amended in 1995, does not permit a party to serve process for indirect contempt by email. The Court further held that substituted service under Rule 4(f) is not permitted in contempt proceedings. Accordingly, the Court made the rule to show cause absolute and remanded the case for further proceedings.