United States v. Hall
United States Court of Appeals for the Fifth Circuit
472 F.2d 261 (5th Cir. 1972)
After a federal district court ordered Duval County, Florida schools desegregated in Mims v. Duval County School Board, violence erupted at one of the schools ordered to integrate, prompting the court to restrain disruptive "outsiders," including Hall (defendant), from entering school grounds on pain of contempt. Hall, though not a party to the underlying Mims litigation, was named in the restraining order and personally served with it. He nonetheless went onto the school grounds, and the court convicted him of criminal contempt. Hall appealed, arguing the court had no power to hold a nonparty in contempt and that Federal Rule of Civil Procedure 65(d) limited the order's binding effect to parties and their agents.
Whether a court has the power to convict a nonparty of criminal contempt for violating a restraining order issued to protect the court's judgment in an underlying case.