In 1995, the Department of Human Resources ("DHR"), on Rhodes behalf, petitioned the Baltimore City Circuit Court ("Circuit Court") for a contempt of court Show Cause Order alleging that Flanagan was in contempt for failing to pay child support as ordered.

The Circuit Court issued a Show Cause Order directing Flanagan to appear at a hearing on September 11, 1995. DHR's process server slid a copy of the Show Cause Order under the door at Flanagan's last known address. Flanagan did not appear at the September 11, 1995 hearing and the Circuit Court issued a contempt arrest warrant for Flanagan.

In 2007, twelve years after the show cause hearing and the issuance of the contempt arrest warrant, Flanagan was arrested. A subsequent show cause hearing was scheduled, where Flanagan was required to explain why he should not be held in contempt for failing to pay child support. Flanagan filed a Motion to Dismiss, arguing that, pursuant to Maryland Rule 2-507(b), the Circuit Court lacked personal jurisdiction over him because he was never personally served with the contempt petition; therefore, he had no notice of the underlying contempt allegation. At the hearing, the Circuit Court denied Flanagan's motion and at that time Flanagan admitted that he was $11,683.47 in arrears on his child support payments. At that time, the Circuit Court held Flanagan in contempt and ordered him to pay the $11,683.47 that he owed in child support arrearage.

Flanagan appealed the matter to the Court of Special Appeals, which affirmed the Circuit Court. Although, the Court of Special Appeals agreed that service of the 1995 Show Cause Order was defective, it held Flanagan's procedural and substantive due process rights were satisfied. The Court of Special Appeals found that the Circuit Court obtained personal jurisdiction over Flanagan in 1987, at the outset of the paternity proceedings and continued to have jurisdiction. Flanagan's Petition for Writ of Certiorari to the Court of Appeals was granted.

The Court of Appeals held that because Flanagan had not received sufficient notice of the Show Cause Order, the Circuit Court had no authority to hold him in contempt and order him to pay the child support arrearage. The Court of Appeals found that sliding the Show Cause Order under the door of Flanagan's last known address was insufficient to notify him of his court date. Relying on a person's last known address is sufficient only with a judge's permission and only after good-faith efforts to notify the defendant have been unsuccessful or if he or she is trying to evade service. Therefore, Flanagan's subsequent admission that he indeed owed $11,683.47 in child support arrearage was nullified.