After a divorce decree required Steve Cook to maintain life insurance and follow a parenting plan, his former wife filed a contempt motion alleging several violations, including substance use and failures involving the child’s care and insurance. The trial court found Cook in contempt and awarded his former wife attorney fees under the statute for conduct lacking substantial justification. The Court of Appeals affirmed the fee award in part, vacated it in part, and remanded. The court held that the trial court could award fees for defenses to the contempt proceeding that were substantially frivolous, groundless, or vexatious. But fees under that statute could not include amounts incurred before the sanctionable defenses were asserted, and the award had to be limited to expenses caused by that conduct. The court also addressed the distinction between pre-litigation conduct and conduct in the proceeding itself. The trial court therefore had to recalculate the award and exclude fees incurred before the husband advanced the deficient defenses. The decision left the contempt judgment intact while narrowing the recoverable fee period.