The Armand Hammer Foundation, Inc. v. Hammer International Foundation

CourtDistrict Court, C.D. California
DecidedSeptember 11, 2023
Docket2:23-cv-01215
StatusUnknown

This text of The Armand Hammer Foundation, Inc. v. Hammer International Foundation (The Armand Hammer Foundation, Inc. v. Hammer International Foundation) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Armand Hammer Foundation, Inc. v. Hammer International Foundation, (C.D. Cal. 2023).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 THE ARMAND HAMMER Case No. 2:23-cv-01215-FLA (SKx) FOUNDATION, INC., 12 ORDER FINDING DEFENDANT Plaintiff, 13 HAMMER INTERNATIONAL v. FOUNDATION TO BE IN 14 CONTEMPT [DKT. 49] 15 HAMMER INTERNATIONAL 16 FOUNDATION, Date: July 14, 2023 Defendant. Time: 1:30 p.m. 17 Courtroom: 6B 18

19 20 ORDER 21 For the reasons stated herein, the court finds and adjudges Defendant Hammer 22 International Foundation (“Defendant” or “HIF”) to be in contempt of the court’s 23 March 20, 2023 Order (Dkt. 34). Plaintiff Armand Hammer Foundation, Inc. 24 (“Plaintiff” or “AHF”) shall file a declaration within fourteen (14) days of this Order, 25 identifying with specificity the attorney’s fees and costs Plaintiff reasonably incurred 26 as a result of HIF’s April 17, 2023 e-mails to Morgan Stanley Smith Barney LLC 27 (“Morgan Stanley”) regarding AHF Account 1317. HIF shall have seven (7) days to 28 file a response to AHF’s declaration. 1 BACKGROUND 2 On March 20, 2023, the court entered a preliminary injunction restraining HIF 3 from transferring, moving, encumbering, or disposing of any asset or property that 4 was actually or purportedly moved, sold, or transferred from Plaintiff AHF to 5 Defendant HIF on or after January 1, 2022 (the “March 20, 2023 Order”). Dkt. 34 at 6 1. The court further enjoined Defendant from interfering with Plaintiff’s access to its 7 financial accounts with Morgan Stanley and ordered that Plaintiff shall have full 8 access to such accounts for purposes of maintaining its operations and paying its 9 employees and contractors (including its attorneys). Id. at 1–2. 10 On April 20, 2023, Plaintiff filed an Ex Parte Application for Contempt and to 11 Enjoin State Court Proceedings (“Ex Parte Application”). Dkt. 43. On April 28, 12 2023, the court granted in part and denied in part the Ex Parte Application and 13 enjoined Defendant from seeking, in the action styled Hammer International 14 Foundation v. Morgan Stanley Smith Barney, LLC et al., Case No. CACE-22017-682 15 in the 17th Judicial Circuit for Broward County, Florida (the “Morgan Stanley 16 Action”) or any other state court proceeding, injunctive relief related to Plaintiff’s 17 access to its accounts with Morgan Stanley. Dkt. 49 at 6.1 The court further ordered 18 Defendant to show cause (“OSC”) why it should not be held in contempt of the 19 court’s March 20, 2023 Order (Dkt. 34), based on HIF’s continued interference with 20 AHF’s access to its accounts with Morgan Stanley. Dkt. 49 at 6. Plaintiff AHF filed 21 a memorandum in support of its request for sanctions. Dkt. 52 (“AHF Mem.”). 22 Defendant HIF filed a response opposing Plaintiff’s request. Dkt. 54 (“HIF Resp.”). 23 The OSC came to hearing on July 14, 2023. Dkt. 84. 24 / / / 25 / / / 26 27 1 In granting the Ex Parte Application, the court noted that its April 28, 2023 Order did not extend to Defendant’s request for a preliminary injunction related to financial 28 accounts in HIF’s name. Dkt. 49 at 6. 1 DISCUSSION 2 I. Legal Standard 3 It is well-established that “courts have inherent power to enforce compliance 4 with their lawful orders through civil contempt.” Shillitani v. United States, 384 U.S. 5 364, 370 (1966); see Chambers v. NASCO, Inc., 501 U.S. 32, 43 (1991). Punishment 6 for civil contempt is usually considered to be remedial and is designed to enforce 7 compliance with a court order. United States v. Powers, 629 F.2d 619, 627 (9th Cir. 8 1980). 9 An order holding a party in contempt is appropriate “[i]f a person disobeys a 10 specific and definite court order” by failing to take “all the reasonable steps within his 11 power to [ensure] compliance with the court’s order.” In re Crystal Palace Gambling 12 Hall, Inc., 817 F.2d 1361, 1365 (9th Cir. 1987) (citing Shuffler v. Heritage Bank, 720 13 F.2d 1141, 1146 (9th Cir. 1983)) (quotation marks and brackets omitted). In the Ninth 14 Circuit, a party alleging that another person should be held in civil contempt must 15 establish by clear and convincing evidence that the alleged contemnor (1) “violated 16 the court order,” (2) “beyond substantial compliance,” (3) “not based on a good faith 17 and reasonable interpretation of the order.” Lab./Cmty. Strategy Ctr. v. L.A. Cnty. 18 Metro. Transp. Auth., 564 F.3d 1115, 1123 (9th Cir. 2009) (quotations omitted). 19 Once a prima facie showing of civil contempt is made, the burden shifts to the 20 alleged contemnor to “produce evidence explaining his noncompliance.” United 21 States v. Ayres, 166 F.3d 991, 994 (9th Cir. 1999) (quotations omitted). While the 22 inability to comply with a court order may be a defense to contempt, the party 23 asserting that defense must show “categorically and in detail” why compliance is 24 impossible. FTC v. Affordable Media, LLC, 179 F.3d 1228, 1240-41 (9th Cir. 1999). 25 It is well-established that a party petitioning for an adjudication that another party is in 26 civil contempt does not have the burden of showing that the other party has the 27 capacity to comply with the court’s order. E.g., NLRB v. Trans Ocean Export 28 Packing, Inc., 473 F.2d 612, 616 (9th Cir. 1973). 1 Civil contempt is generally viewed under an objective standard, and “a party’s 2 subjective belief that she was complying with an order ordinarily will not insulate her 3 from civil contempt if that belief was objectively unreasonable.” Taggart v. Lorenzen, 4 139 S. Ct. 1795, 1802 (2019). As the purpose of civil contempt is remedial, 5 willfulness is not a necessary element for civil contempt. Perry v. O’Donnell, 759 6 F.2d 702, 705 (9th Cir. 1985) (citing, e.g., McComb v. Jacksonville Paper Co., 336 7 U.S. 189, 191 (1949)). Ordinarily, “[i]t does not matter what the intent of the [party] 8 was when [it] violated the court’s order.” In re Crystal Palace, 817 F.2d at 1365 9 (citing McComb, 336 U.S. at 191). 10 Nevertheless, courts may consider a noncompliant party’s subjective intent in 11 making a contempt determination, as “civil contempt sanctions may be warranted 12 when a party acts in bad faith,” and “a party’s good faith, even where it does not bar 13 civil contempt, may help to determine an appropriate sanction.” Taggart, 139 S. Ct. at 14 1802 (citations omitted); see also Stone v. City & County of San Francisco, 968 F.2d 15 850, 856-57 (9th Cir. 1992) (In determining whether a party performed “all reasonable 16 steps within their power to [ensure] compliance,” courts have considered factors 17 including “the [party’s] history of noncompliance” and “the failure to comply despite 18 the pendency of the contempt motion.”), cert. denied, 506 U.S. 1081 (1993). “[A] 19 party’s record of continuing and persistent violations and persistent contumacy 20 justifie[s] placing the burden of any uncertainty in the decree … on [the] shoulders of 21 the party who violated the order.” Taggart, 139 S. Ct. at 1802 (quotations omitted). 22 II.

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Related

Brookhart v. Janis
384 U.S. 1 (Supreme Court, 1966)
Chambers v. Nasco, Inc.
501 U.S. 32 (Supreme Court, 1991)
In Re Crystal Palace Gambling Hall, Inc.
817 F.2d 1361 (Ninth Circuit, 1987)
United States v. Jose Vaz Ayres
166 F.3d 991 (Ninth Circuit, 1999)
Taggart v. Lorenzen
587 U.S. 554 (Supreme Court, 2019)
Torrey v. Wolfes
6 F.2d 702 (D.C. Circuit, 1925)
Federal Trade Commission v. Affordable Media, LLC
179 F.3d 1228 (Ninth Circuit, 1999)

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The Armand Hammer Foundation, Inc. v. Hammer International Foundation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-armand-hammer-foundation-inc-v-hammer-international-foundation-cacd-2023.