In Dodson v. Dodson, 380 Md. 438, 452, 845 A.2d 1194 (2004), an ex-husband violated a court order to pay property insurance, which resulted in financial losses for his ex-wife when a fire damaged the uninsured property. Id. at 444. The Court of Appeals vacated a civil contempt order requiring the ex-husband to pay compensatory damages to reimburse his ex-wife, because the purpose of that order was not "to coerce the contemnor's present or future compliance with the earlier . . . order," given that the order "contained no purging provision" and did not require the ex-husband to do anything other than pay money. Id. at 451. The Dodson Court held that a civil contempt sanction cannot be imposed as compensation for damages caused by a contemnor's negligent violation of a court order. Id. at 440. The Court of Appeals of Maryland ruled on an issue of first impression, namely "whether compensatory damages may be awarded in a civil contempt action." Id. at 445. After exhaustively reviewing cases concerning civil contempt, the Court stated "under settled Maryland law, one may not be held in contempt of court unless the failure to comply with the court order was or is willful." Id. at 452. The Court specifically held "compensatory damages may not ordinarily be recovered in a civil contempt action." Id. at 454. The Court explained, though, the issue in Dodson was not "whether, under exceptional circumstances, a willful violation of a court order, clearly and directly causing the plaintiff a monetary loss, could form the basis for a monetary award in a civil contempt case." Id. The Court held that "compensatory damages may not ordinarily be recovered in a civil contempt action," and "may never be recovered in a civil contempt action based upon a past negligent act by the defendant." Id. at 454. In that case, Mr. Dodson negligently failed to pay an insurance premium for Ms. Dodson's personal property as required in a pendente lite order. Id. at 441. A fire broke out in the condominium, and the failure to pay the insurance prevented Ms. Dodson from recovering insurance money on her lost personal property. Id. Ms. Dodson filed a contempt action, and the circuit court awarded her $ 19,311 in compensatory damages. Id. at 444. In reversing the circuit court's order, the Court of Appeals reasoned that the monetary award "cannot be reconciled" with the purpose of civil contempt because the award was not intended to "coerce the defendant's present or future compliance with the earlier pendente lite order." Id. at 451. Rather, the purpose of the award "was to impose a sanction" "for a past failure to comply with a court order." Id. at 452. The Court of Appeals also noted that the lawsuit, "although labeled a civil contempt action, was in essence a tort suit for money damages," but the circuit court denied the husband's request for a jury trial because it was a contempt action. Id. at 453. The Court of Appeals concluded that "compensatory damages may never be recovered in a civil contempt action based upon a past negligent act by the defendant." Id. at 454. The Court went on to note, however, that the case did not present the issue of "whether, under exceptional circumstances, a willful violation of a court order, clearly and directly causing the plaintiff a monetary loss, could form the basis for a monetary award in a civil contempt case. We shall leave the resolution of that question for another day." Id. at 454.