California, United States of America
The following excerpt is from Moss v. Superior Court, 49 Cal.App.4th 871, 56 Cal.Rptr.2d 864 (Cal. App. 1996):
11 At the hearing, the trial court spoke briefly of "later cases" but respondent cites none but People v. Dilday, supra, 20 Cal.App.4th Supp. 1, 25 Cal.Rptr.2d 386. However, the only pertinent holding of the case is simply that inability to pay is an affirmative defense, following In re Feiock. It says nothing about the effect of a contemnor's failure to seek or obtain employment on ability to pay.
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