Brown v. City of Upper Arlington

Brown (plaintiff) sued in state court and obtained a temporary restraining order to stop the City of Upper Arlington (defendant) from cutting down a tree near his home; the city removed the case to federal court, which then dismissed the federal claims without ruling on the state claims. Brown told the city he intended to refile in state court, but shortly after the dismissal, the city cut down the tree anyway. Brown moved to hold the city in contempt; the district court used its inherent powers to grant the motion, and the city appealed.