In In re Green, 221 S.W.3d 645, 646 (Tex. 2007), the wife sought enforcement of the contractual spousal support provisions referenced in the divorce decree. Id. at 646. The trial court ordered the husband confined to jail until he paid the spousal support arrearage. Id. at 647. The supreme court held that failure to pay a private alimony debt is not contempt punishable by incarceration. Id. A legal obligation to support a spouse is enforceable by contempt, but a promise to pay contractual alimony creates nothing more than a debt. Id. at 648. The Texas Supreme Court addressed an analogous issue involving an agreement for spousal support that was included within a divorce decree. The court concluded that because the spousal support in question was ordered solely on the basis of the parties' agreement, and was not "spousal maintenance" as authorized by the Family Code, contempt was not an available enforcement mechanism. 221 S.W.3d at 646-49. In In re Green, the supreme court interpreted the cited Family Code section relating to spousal maintenance as authorizing enforcement by contempt only if the agreement meets the Family Code's other requirements for spousal maintenance, and expressly rejected the argument that authorized enforcement by contempt of any agreement to pay spousal maintenance. 221 S.W.3d at 648. The Court reaffirmed that to the extent a voluntary agreement regarding support exceeds a party's legal duty of support, it is a contractual debt that cannot be enforced by contempt. Id.