What is the test for contempt of court for failing to transfer a Jetta to a new mortgage holder?

For a finding of contempt, there must be some element of intent by the Respondent to breach the court order: see Carey v. Laiken, supra. It is clear that an accidental breach will not support a finding of contempt. It may as well be the case that a breach of the order resulting from circumstances beyond the Respondent’s control will also not support a finding of contempt. It is unclear to me from the material filed as to whether the breach was intentional or wilful as it is unclear as to what the Respondent’s assets are today, and as to the real reasons as to the inability of the Respondent to refinance. Also, neither party’s material addressed in any meaningful fashion the failure to transfer the Jetta.