Jessica Hall v. Laddin Cole Mock

── Jessica Hall v. Laddin Cole Mock ── Court: Court of Civil Appeals of Alabama Date: May 22, 2026 Author: Moore Category: General Rel: May 22, 2026 Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is published in Southern Reporter. ALABAMA COURT OF CIVIL APPEALS OCTOBER TERM, 2025-2026 _________________________ CL-2025-0417 _________________________ Jessica Hall v. Laddin Cole Mock Appeal from Geneva Circuit Court (DR-17-900010.03) MOORE, Presiding Judge. Jessica Hall appeals from a judgment entered by the Geneva Circuit Court ("the circuit court") finding her in contempt of court and modifying the custody of her child with Laddin Cole Mock. Because the circuit court lacked jurisdiction to enter the judgment, we dismiss this CL-2025-0417 appeal, albeit with instructions for the circuit court to vacate the judgment. Procedural History In January 2019, the circuit court determined that Mock was the legal father of the parties' child, awarded the parties joint legal custody of the child, awarded sole physical custody of the child to Hall, subject to certain visitation rights awarded to Mock,1 and ordered Mock to pay child support to Hall. In February 2023, Mock filed a petition in the circuit court, seeking an order holding Hall in contempt for allegedly interfering with his visitation rights under the 2019 judgment and requesting that the circuit court modify the custody of the child; that petition was assigned case number DR-17-900010.03 ("the .03 action"). On March 30, 2023, Mock amended his petition in the .03 action to assert a second count for contempt. Hall filed an answer and a counterclaim to modify Mock's visitation rights. 1In the 2019 judgment, the circuit court awarded Mock the right to visit with the child at reasonable times and reasonable places upon giving Hall reasonable notice. In addition, the circuit court established a visitation schedule that gave Mock the right to visit with the child every other weekend, one month during the summer, and on certain holidays. 2 CL-2025-0417 On March 15, 2024, the circuit court entered a judgment in the .03 action, citing Hall for contempt, ordering her to pay $2,500 toward Mock's attorney's fees, and directing Hall to "follow the visitation order in place." The March 15, 2024, judgment further provided that "[a]ll other motions, petitions or claims for relief, by either party, not granted herein, are denied." On April 11, 2024, Mock filed in the .03 action a motion titled "Motion for Sanctions." In that motion, Mock alleged that Hall had refused to allow him to pick up the child for visitation on March 29, 2024, in violation of the March 15, 2024, judgment entered in the .03 action. Mock requested that the circuit court sanction Hall and order her to pay his attorney's fees. On April 11, 2024, Hall filed a response to the motion, denying that she had disobeyed the operative visitation order; Hall later amended her response to clarify that she was following the visitation schedule in the 2019 judgment and to request that the circuit court order Mock to pay her attorney's fees. On June 12, 2024, the circuit court held a hearing on the motion for sanctions. On June 14, 2024, the circuit court entered an order, granting the motion. That order provides, in pertinent part: 3 CL-