In Bank of Guam v. Ruben, 2008 MP 22, 8 N. Mar. I. 165, the Court was presented with a situation where a debtor was held in contempt for failing to make monthly payments on a debt, but the jail sentence was suspended on the condition that the debtor seek employment.
At the first review hearing, the debtor had complied with the job search provision, but at a second hearing the trial court found that she had not continued to fill out employment applications.
The debtor was then held in contempt, and while the court threatened her with a jail sentence, it again declined to impose one.
The issue before the Court was whether the trial court denied the debtor her due process rights when it held her in contempt without the assistance of counsel.
The Court held that contemnors who face a potential loss of liberty are entitled to counsel. Id.