Questions Presented
1. Whether a court may hold a party in civil contempt based on a violation of an injunction’s “spirit” where the injunction is silent as to the conduct upon which contempt is based, as the Ninth Circuit holds; or, instead, whether a court must ground a finding of civil contempt on the violation of an order that clearly and unambiguously proscribes the precise conduct at issue, as other circuits hold.
2. Whether the Ninth Circuit has properly created an “antitrust” or “competition” exception to Trump v. CASA, Inc., 606 U.S. 831 (2025), and the longstanding equitable principles on which CASA rests, or otherwise disregarded CASA’s limits.
Case Updates
U.S. Chamber files amicus brief urging Supreme Court to hold that a court may not hold a party in civil contempt for violating an injunction’s “spirit” and, rather, may do so based only on a violation of the injunction’s text.
September 21, 2026
Sopen B. Shah of Eimer Stahl LLP served as outside counsel.