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United States v. Hall - 472 F.2d 261 (5th Cir. 1972)

Rule:

Courts have jurisdiction to punish for contempt in order to protect their ability to render judgment. The same principle applies in the use of in rem injunctions. Federal courts may issue injunctions binding on all persons, regardless of notice, who come into contact with property which is the subject of a judicial decree. A court entering a decree binding on a particular piece of property is necessarily faced with the danger that its judgment may be disrupted in the future by members of an undefinable class, those who may come into contact with the property. The in rem injunction protects the court's judgment.

Facts:

A federal district court entered an ex parte order to prevent further disruption of a school desegregation plan involving several schools, including a Ribault Senior High School ("Ribault"). The district court subjected its order to anyone having notice who violated the order and required that the order be served to several named persons, including defendant Eric Hall, a nonparty to the underlying desegregation case. Hall allegedly was a member of a militant organization who, in combination with African-American students and parents, were attempting to prevent the normal operation of Ribault through student boycotts and other activities. Hall was arrested after willfully violating the order by appearing on the Ribault campus. After a nonjury trial, the district court found Hall guilty of the charge of criminal contempt and sentenced him to 60 days' imprisonment. The district court found that Hall, though not a party in the underlying cause, violated a court order designed to protect the judgment in the school desegregation case. Hall appealed.

Issue:

Could the district court exercise its contempt power over a person who was not a party in the case in which an ex parte order had been entered?

Answer:

Yes.

Conclusion:

The appellate court affirmed the district court's judgment. The court held that the district court had the inherent power to protect its ability to render a binding judgment between the original parties in the school desegregation case by issuing an interim ex parte order against an undefinable class of persons. The court further held that willful violation of that order by one having notice of it, such as Hall, constituted criminal contempt.

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