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Yntema v. Smith

2024-09-17

Summary

Holding. The Supreme Court denied the petition for certiorari.

The Georgia Supreme Court declined to review a lower court decision involving a speech restriction order issued in a family law case. The case centered on a trial court order that broadly prohibited certain speech by multiple individuals. While the petitioner consented to the order, his wife was not a party to the original litigation and did not consent, raising questions about whether the order could bind her.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether a trial court order restricting speech can bind a nonparty who did not consent
  • Constitutional validity of broad prior restraints on speech in family law proceedings
  • Due process rights of nonparties to consent orders
  • Applicability of nondisparagement orders between divorced parents

Procedural posture

The Supreme Court reviewed a petition for certiorari to challenge a Court of Appeals decision affirming a trial court's speech restriction order in a family matter.

Authorities cited

Opinion

majority opinion

NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and official text of the opinion.

SUPREME COURT OF GEORGIA

Case No. S24C0850

September 17, 2024

The Honorable Supreme Court met pursuant to adjournment.

The following order was passed:

HOWARD RUSSELL YNTEMA v. LEAH SMITH.

The Supreme Court today denied the petition for certiorari in

this case.

All the Justices concur.

Court of Appeals Case No. A23A1660

SUPREME COURT OF THE STATE OF GEORGIA

Clerk’s Office, Atlanta

I certify that the above is a true extract from the

minutes of the Supreme Court of Georgia.

Witness my signature and the seal of said court hereto

affixed the day and year last above written.

, Clerk

PETERSON, Presiding Justice, concurring.

I concur fully in the denial of Howard Yntema’s petition for a

writ of certiorari. Although there is gravity in whether the order of

the trial court prohibiting a broad range of speech by a variety of

people was permitted by the federal and state constitutional rights

to free speech, Yntema consented to that order (and so waived

whatever rights the order might otherwise have violated). But Kitty,

Yntema’s new wife, was not a party to the litigation, and did not

consent to the order.

It seems to me that Kitty’s challenges to the order — both on

free speech grounds and on due process grounds as a nonparty —

are significant. And I have serious doubts about aspects of the Court

of Appeals’s resolution of those challenges. 1 But Kitty has not filed

1 As to the due process issue, the case law on which the court relied for a

trial court’s authority to hold a nonparty in contempt does not seem to apply.

The Court of Appeals concluded that the consent order applied to Kitty merely

because she had notice of it. Notice is a necessary condition, but is not sufficient alone. The sole case the Court of Appeals cited in which a contempt order was

upheld involved a nonparty taking extraordinary efforts to frustrate orders of

the trial court, and then being held in contempt for those efforts. See Wilkerson

v. Tolbert, 239 Ga. 702 (238 SE2d 338) (1977). The Court of Appeals cited no

decision of our Court empowering trial courts to include nonparties within the

2

a petition for a writ of certiorari, and this is not the sort of case

warranting the exercise of our certiorari power sua sponte. And, in

scope of an order like the one here absent some previous effort to impede the

trial court’s lawful authority.

And as to the free speech issue, the Court of Appeals properly recognized

that at least some of the trial court’s order was constitutionally impermissible.

But it applied a decision of our Court for the proposition that it is

constitutionally permissible for a trial court to require parties in a divorce

proceeding “to refrain from making derogatory remarks about the other before

the children.” See Maloof v. Maloof, 231 Ga. 811, 812 (6) (204 SE2d 162) (1974).

That statement in Maloof cited no authority, Maloof has never been cited by

our Court, and the statement was dicta, given the Court’s holding that the

order at issue was not permissible. And, in any event, Maloof’s conclusory dicta

was limited by its terms to parties. It is not at all clear that broad prior

restraints such as those here (which extended far beyond statements made in

the presence of the children) would satisfy the constitutional rights to free

speech. See, e.g., K. Gordon Murray Prods. v. Floyd, 217 Ga. 784, 790-793 (2)

(125 SE2d 207) (1962) (holding that prior restraint that was permissible under

United States Constitution was impermissible under Georgia Constitution);

see also Shak v. Shak, 144 NE3d 274, 279-280 (Mass. 2020) (considering

nondisparagement order in divorce proceeding under First Amendment and

holding that, although “the State has a compelling interest in protecting

children from being exposed to disparagement between their parents,” order

was impermissible prior restraint because no case-specific showing was made

“linking communications by either parent to any grave, imminent harm to the

child” (citations and punctuation omitted)); Yanez v. Sanchez, 548 P3d 341, 345

(Ariz. Ct. App. 2024) (while considering First Amendment challenge to order

imposing speech restrictions in domestic case, observing “nearly every state to

have tackled the issue requires proof of actual or threatened physical or

emotional harm to a child” and invalidating order due to lack of record

“evidence of actual or threatened physical or emotional harm to the child”)

(citing cases).

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any event, as the Court of Appeals rightly noted, its review was very

limited given that the trial court order on appeal is interlocutory. It

may be that Kitty can more persuasively raise constitutional

challenges before the trial court on remand; although the Court of

Appeals’s narrow decision will be law of the case in future

proceedings before the trial court and the Court of Appeals as to the

issues actually decided, it does not prevent either court from

considering broader issues on remand, and does not prevent our

consideration of an eventual cert petition even as to the issues

already decided by the Court of Appeals.

I am authorized to state that Justice Warren and Justice

LaGrua join in this concurral.

4