JYSK Bed'N Linen v. Monosij Dutta-Roy
714 F. App'x 920
| 11th Cir. | 2017Background
- Jysk Bed’N Linen obtained partial summary judgment in district court requiring Monosij Dutta‑Roy to transfer disputed domain names to Jysk.
- Dutta‑Roy appealed the partial summary judgment and thereafter refused to transfer the domain names as ordered.
- The district court held Dutta‑Roy in civil contempt, ordered him to pay attorney’s fees to Jysk, and threatened a prospective fine for continued noncompliance.
- Dutta‑Roy challenged all subsequent district‑court orders (and some state garnishment proceedings) on appeal, arguing lack of jurisdiction because of his earlier appeal.
- The Eleventh Circuit limited its review to the contempt/fee orders (prior nonfinal orders were governed by law‑of‑the‑case and district court retained enforcement jurisdiction), found the prospective fine moot (transfer completed), affirmed contempt, and vacated/remanded the attorney‑fees award for lack of adequate supporting analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court retained jurisdiction to enforce the partial summary judgment after appeal | Dutta‑Roy: appeal divested district court of jurisdiction over subsequent orders | Jysk: absent a stay, district court may enforce its orders | District court retained jurisdiction to enforce the nonfinal partial summary judgment; state garnishment review was beyond its authority |
| Whether the contempt finding was proper | Dutta‑Roy: contempt improper because the underlying summary‑judgment order was erroneous | Jysk: contempt proper because Dutta‑Roy disobeyed a clear, valid order and could comply | Affirmed: contempt supported by clear and convincing evidence; order was valid, clear, and defendant had ability to comply |
| Whether the prospective fine remained appealable or was moot | Dutta‑Roy: (sought relief) | Jysk: fine was a remedy for continued disobedience | Moot: fine never imposed and domain names were transferred, so no live controversy |
| Whether the attorney’s‑fee award was proper | Dutta‑Roy: district court lacked jurisdiction to award fees while appeal pending; fees were not requested in complaint | Jysk: fee award appropriate as remedy for contempt | Vacated and remanded: district court abused discretion by awarding $2,150 without record support or fee‑analysis; requires reconsideration |
Key Cases Cited
- Sergeeva v. Tripleton Int’l Ltd., 834 F.3d 1194 (11th Cir. 2016) (district court retains jurisdiction to enforce orders absent a stay)
- Nicholson v. Shafe, 558 F.3d 1266 (11th Cir. 2009) (federal courts generally cannot review final state‑court judgments)
- Combs v. Ryan’s Coal Co., 785 F.2d 970 (11th Cir. 1986) (distinguishing appealability of coercive contempt fines that can be purged versus fixed penalties)
- Riccard v. Prudential Ins. Co., 307 F.3d 1277 (11th Cir. 2002) (civil contempt standard: clear and convincing evidence; elements require valid, clear order and ability to comply)
- F.T.C. v. Leshin, 618 F.3d 1221 (11th Cir. 2010) (willfulness not required for civil contempt; focus is on compliance)
- Davis v. Nat’l Med. Enter., Inc., 253 F.3d 1314 (11th Cir. 2001) (attorney’s‑fees award reviewed for abuse of discretion)
- Jysk Bed’N Linen v. Dutta‑Roy, 810 F.3d 767 (11th Cir. 2015) (prior appellate ruling relevant under law‑of‑the‑case)