Jamal Kifafi v. Hilton Hotels Retirement Plan, 21-7025

Over two decades earlier Kifafi sued Hilton under ERISA, and the District Court entered a permanent injunction in 2011 to remedy violations; the D.C. Circuit affirmed remedial orders in 2012.
The District Court later found Hilton in compliance and in December 2015 ended its "active supervision," stating that its "jurisdiction" over the matter had concluded.
In 2019 this Court clarified that ending active supervision does not terminate the underlying permanent injunction and that class members retain enforcement rights.
In May 2020 Kifafi moved to reopen the case seeking contempt proceedings and an equitable accounting; the District Court denied the motion in March 2021 solely because it believed its jurisdiction ended in 2015.
On appeal, the D.C. Circuit declined de novo review but held the District Court abused its discretion by denying the motion on the wrong legal ground, vacated the 2021 Order, and remanded for further proceedings.
The Circuit reaffirmed that a district court retains authority to enforce a permanent injunction even after it stops active supervision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a district court retains authority to enforce a permanent injunction after ending active supervision	Kifafi: Ending active supervision does not eliminate the court's power to enforce the injunction; class members retain enforcement rights	Hilton: District Court lost jurisdiction when it terminated the case in 2015 and therefore lacked power to act	Held: District court retains enforcement authority; termination of active supervision does not bar enforcement actions
Appropriate standard of appellate review for denial of enforcement motion	Kifafi: District Court provided no discretionary assessment of evidence, so de novo review is warranted	Hilton: Abuse-of-discretion review is appropriate	Held: Court applies abuse-of-discretion review but reviews whether the district court applied the correct legal standard
Whether denying enforcement solely because "jurisdiction ended" was proper	Kifafi: That rationale conflicts with this Court's 2019 decision and is legally incorrect	Hilton: Implied other substantive reasons justified denial (though not stated in the order)	Held: Denial based solely on termination of jurisdiction was an abuse of discretion; vacated and remanded

Kifafi v. Hilton Hotels Ret. Plan, 701 F.3d 718 (D.C. Cir. 2012) (affirming district court remedial orders)
Kifafi v. Hilton Hotels Ret. Plan, [citation="752 F. App'x 8"] (D.C. Cir. 2019) (ending active supervision does not terminate the underlying permanent injunction; class members retain enforcement rights)
Marshall v. Local Union No. 639, 593 F.2d 1297 (D.C. Cir. 1979) (federal courts have unquestioned power to protect and enforce their judgments)
Sims v. Johnson, 505 F.3d 1301 (D.C. Cir. 2007) (district court remedial decisions are entitled to deference)
Peyton v. DiMario, 287 F.3d 1121 (D.C. Cir. 2002) (standards for reviewing abuse of discretion)
Amador Cnty. v. U.S. Dep't of the Interior, 772 F.3d 901 (D.C. Cir. 2014) (a district court abuses its discretion when it applies the wrong legal standard)