National Ass'n for the Advancement of Colored People v. Bass, 2017 Ark. App. 166

In 2010 the Crittenden County NAACP branch held an election; incumbents lost but the former president and national NAACP challenged the results.
Raymond Abramson’s circuit court entered interim orders (Feb. 17, 2011; Mar. 31, 2011) validating the 2010 election and warning third parties (including national NAACP) not to interfere.
National NAACP sent multiple letters (Oct. 26, 2011; Nov. 2013; Mar. 2014) suspending or revoking the branch’s charter and membership, and denied the branch full participation in state activities.
Hubert Bass (on behalf of the branch) moved for contempt, injunction, and damages; NAACP intervened on April 12, 2011.
After hearings the circuit court found the NAACP in civil contempt for willfully violating court orders, awarded $100,000 plus $20,000 in attorney’s fees, and imposed a three-year preclearance oversight requirement on NAACP actions regarding the branch.
The Arkansas Court of Appeals affirmed: contempt was supported by disobedience of earlier orders (and by effect of intervention), preclearance was within the court’s authority in the extraordinary circumstances, and the continuance and fee rulings were not reversible.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether contempt finding was supported	Branch: NAACP willfully disobeyed court orders and harmed branch; sanction warranted	NAACP: no violation of any order applicable to it; some orders expired or were not directed to NAACP	Court: contempt upheld — NAACP became subject to earlier orders by intervening and its conduct violated injunctions; sanction affirmed
Whether orders entered before intervention bound NAACP	Branch: earlier orders were aimed at national NAACP and applied	NAACP: could not be held to orders entered before it became a party; some orders were temporary/ex parte and expired	Court: orders (Feb. 17 and Mar. 31, 2011) referenced national NAACP and were directed at it; intervenor is bound by prior orders; some ex parte order questions not dispositive
Authority to impose three-year preclearance oversight	Branch: oversight necessary due to persistent disobedience and management difficulties	NAACP: courts generally cannot oversee voluntary associations absent fraud or compelling reason	Court: in these extraordinary, protracted circumstances oversight/preclearance was within court authority
Due process re: denial of continuance and attorney’s fees	NAACP: denial of continuance deprived due process; fee award improper	Branch: NAACP had notice and opportunity; fees authorized in contempt proceedings	Court: no abuse of discretion in denying continuance; inherent power supports fee award; both affirmed

Balcom v. Crain, 496 S.W.3d 405 (Ark. Ct. App. 2016) (distinguishing civil vs. criminal contempt and standard of review)
Ransom v. JMC Leasing Specs., LLC, 505 S.W.3d 737 (Ark. Ct. App. 2016) (civil contempt may compensate party for injuries from disobedience)
Riddick v. Harris, 501 S.W.3d 859 (Ark. Ct. App. 2016) (injunctions must be definite and clear to support contempt)
Allen v. Allen, 259 S.W.3d 480 (Ark. Ct. App. 2007) (an order is effective only when entered)
Ex parte Price, 741 S.W.2d 366 (Tex. 1987) (cannot be held in contempt for violating an order not yet entered)
Gravett v. McGowan, 886 S.W.2d 606 (Ark. 1994) (intervenor is treated as original party and bound by prior orders)
Omni Holding & Dev. Corp. v. 3D.S.A., Inc., 156 S.W.3d 228 (Ark. 2004) (nonparties with notice of injunction may be held in contempt)
Scudder v. Ramsey, 426 S.W.3d 427 (Ark. 2013) (trial court has inherent power to award attorney's fees in contempt proceedings)
Arkansas Activities Ass'n v. Meyer, 805 S.W.2d 58 (Ark. 1991) (limits on court review of voluntary associations absent fraud or compelling reason)