Brown v. City of Upper Arlington, 637 F.3d 668

40-year-old tree on city property adjacent to Brown's home; City planned to cut due to decay; Brown contested before Tree Commission and state court; case removed to federal court; district court denied injunction and Brown sought to refile in state court; City cut the tree after dismissal and Brown moved for contempt alleging violation of court processes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the City’s tree-cutting violated a court order or stay	Brown contends conduct violated the court’s order/judicial stay	City argues no order or automatic stay existed to violate	No contempt; no order or automatic stay violated
Whether the federal court had inherent contempt power	Brown relies on Chambers to sanction for jurisdictional subversion	Inherent power does not apply absent order or ongoing jurisdiction	Inherent power not applicable to conduct after dismissal or absent an order
Whether the district court could sanction after dismissal to protect jurisdiction	Actions aimed to preserve jurisdiction and prevent review	Post-dismissal acts not sanctionable under inherent power	No sanction under inherent power; vacate and remand

Chambers v. NASCO, Inc., 501 U.S. 32 (Supreme Court, 1991) (inherent power limited to protect court jurisdiction and sanction misuse)
Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (Supreme Court, 1994) (jurisdictional limits of inherent authority after dismissal)
Merrimack River Sav. Bank v. City of Clay Center, 219 U.S. 527 (Supreme Court, 1911) (continuing injunctions; no automatic stay after appeal if no injunction)
Roadway Express, Inc. v. Piper, 447 U.S. 752 (Supreme Court, 1980) (contempt for willful disobedience of court orders)
Young v. U.S. ex rel. Vuitton & Co., 481 U.S. 787 (Supreme Court, 1987) (contempt power to enforce judgments and orders)
Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343 (Supreme Court, 1988) (remand and jurisdictional considerations when federal court dismisses claims)