Surcharge Payments Enforceable by Civil Contempt

The Orphans’ Court has the power to enforce through civil contempt an order requiring a former fiduciary to pay a surcharge in installments, and may order incarceration for the former fiduciary when he contemptuously fails to make the required payments, the restrictions of 42 Pa.C.S. §§ 4132 and 4133 only applying to summary punishments for criminal contempts. In re: Estate of Helen J. DiSabato, 2017 PA Super 185 (6/13/2017).

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