Dhane Brooks Dingle and Horacio Carter filed cross-motions for contempt concerning custody, child support, and attorney fees. Their custody order gave Dingle primary physical custody but required her to notify Carter if her military deployment would occur, and it provided for Carter’s support and other obligations. The trial court held Dingle in contempt, adjusted part of Carter’s support obligation, and awarded Carter attorney fees. The Court of Appeals affirmed in part, reversed in part, and remanded. It held that a trial court cannot award fees under the general litigation-sanctions statute without an evidentiary hearing to determine reasonable and necessary fees. It also held that the statute authorizing fees in alimony and divorce cases did not apply because this was a custody and contempt dispute, not an alimony or divorce case. The fee award was therefore reversed. The mixed ruling preserved some of the trial court’s custody and support determinations while requiring correction of the fee rulings and other portions of the contempt judgment.