Civil contempt is only appropriate when the imposed party has the power to comply with the underlying order.[20] Controversial contempt rulings have periodically arisen from cases involving asset protection trusts, where the court has ordered a settlor of an asset protection trust to repatriate assets so that the assets may be made available to a creditor.[21] A court cannot maintain an order of contempt where the imposed party does not have the ability to comply with the underlying order.