South Dakota Codified Laws 25-4A-4. Affirmative defense by contemnor
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An alleged contemnor may plead and prove that the movant voluntarily relinquished the actual care, control, and possession of the child for time encompassed by the court–ordered periods of possession. Such a relinquishment is an affirmative defense in whole or part to the order to show cause.
Source: SL 1994, ch 195, § 4.