Bank of New York v. Bell, 142 Conn. App. 125

Bank of New York, as trustee for BS ALT A 2005-9, was held in contempt on December 16, 2010 for failing to fully respond to discovery over more than a year.
Contempt was based on alleged violations of prior orders requiring interrogatories and production, including omission of hundreds of pages.
The trial court interpreted discovery as extending beyond BS ALT A 2005-9 to the entire JP Morgan Chase–Bank of New York transaction.
Bank of New York argued the court lacked authority to compel nonparty documents or to compel responses on behalf of Bank of New York as trustee for trusts other than BS ALT A 2005-9.
The appellate court held the contempt judgment improper because the court ordered production of documents belonging to a nonparty, and remanded to vacate the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court had authority to compel nonparty documents.	Bank of New York contends the order improperly extended to nonparties.	Bells contend the discovery scope encompassed the entire transaction.	Court abused discretion; order exceeded authority and was improper.
Whether the contempt judgment was based on an overly broad discovery order.	BNY asserts the scope included entities/assets not party to the action.	Court allowed broad inquiry into all assets/transactions challenged by the defendants.	Judgment of contempt reversed for overbreadth.

Millbrook Owners Assn., Inc. v. Hamilton Standard, 257 Conn. 1 (Conn. 2001) (clear, unambiguous orders and proportional sanctions for contempt)
In re Leah, 284 Conn. 685 ( Conn. 2007) (two-step test for contempt: clarity of order and abuse of discretion in sanctioning)
Tanzman v. Meurer, 128 Conn. App. 405 ( Conn. App. 2011) (contextual treatment of appellate review limits)
Follacchio v. Follacchio, 124 Conn. App. 371 ( Conn. App. 2010) (guidance on scope of discovery and contempt)