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0:23-cv-03255
D. Minnesota
Jun 23, 2025
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Background

  • Data Axle, Inc. sued CFM Data Network, LLC (d/b/a DataSourceOne.com), its owner Andrew Nolting, and others, and obtained a default judgment against CFM/DSO.
  • After the judgment, Data Axle sought contempt sanctions, arguing CFM/DSO and Nolting violated the court’s previous orders.
  • The court imposed a $1,000-per-day contempt sanction against Nolting (as DSO’s sole owner) until DSO complied with obligations, set to begin May 31, 2025.
  • Nolting moved to stay these sanctions pending his appeal to the Eighth Circuit.
  • The court temporarily stayed enforcement of sanctions to consider Nolting’s motion.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Is Nolting likely to succeed on the merits of his appeal? No jurisdiction for interlocutory appeal; sanctions proper. Appeal should be allowed; sanctions are improper against him. Not likely; Eighth Circuit lacks jurisdiction; appeal premature.
Will Nolting suffer irreparable harm without a stay? No irreparable harm; monetary loss recoverable. $1,000/day is severe, unrecoverable if reversed. No irreparable harm; loss is economic and recoverable.
Does the collateral-order doctrine allow appeal now? Does not apply here; order is not final nor unreviewable. Doctrine applies; order meets criteria for immediate appeal. Doctrine does not apply; order is not conclusive or separate from merits.
Should contempt be used to enforce a money judgment? Sanctions are proper under precedent. Contempt is improper for collecting ordinary money judgment. Court inclined to amend order to remove payment-related contempt, but lacks jurisdiction during appeal.

Key Cases Cited

  • Nken v. Holder, 556 U.S. 418 (standards for grant of stay pending appeal)
  • Cunningham v. Hamilton County, 527 U.S. 198 (finality requirement for appealable orders)
  • Mohawk Indus., Inc. v. Carpenter, 558 U.S. 100 (final judgment principles)
  • Coca-Cola Co. v. Purdy, 382 F.3d 774 (appealability of contempt orders)
  • Chi. Truck Drivers v. Bhd. Lab. Leasing, 207 F.3d 500 (holding owner in contempt for company’s failure to pay under ERISA)
  • Combs v. Ryan’s Coal Co., 785 F.2d 970 (contempt not proper to enforce ordinary money judgment)
  • Digit. Equip. Corp. v. Desktop Direct, Inc., 511 U.S. 863 (collateral-order doctrine is narrow exception to finality rule)
  • Midland Asphalt Corp. v. United States, 489 U.S. 794 (requirements for collateral-order doctrine)
  • Will v. Hallock, 546 U.S. 345 (collateral-order doctrine and substantial public interest)
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Case Details

Case Name: Data Axle, Inc. v. CFM Data Network, LLC
Court Name: District Court, D. Minnesota
Date Published: Jun 23, 2025
Citation: 0:23-cv-03255
Docket Number: 0:23-cv-03255
Court Abbreviation: D. Minnesota
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    Data Axle, Inc. v. CFM Data Network, LLC, 0:23-cv-03255