RSL Funding, LLC v. Date, 15-03185

In 1996 the court entered a permanent injunction barring Stewart A. Feldman and entities he owns from filing adversary proceedings in bankruptcy court without leave, based on prior vexatious litigation.
RSL Funding, LLC (an entity owned by Feldman) filed the instant adversary proceeding in 2015 without first obtaining leave of the court.
Defendant orally moved to dismiss the adversary proceeding as a violation of the 1996 injunction; the Court dismissed the adversary proceeding for that reason.
Plaintiff moved for reconsideration/new trial/alter-or-amend judgment, arguing the 1996 injunction was invalidated or unenforceable after the District Court’s withdrawal of the reference in related cases and that sanctions issues altered the injunction’s scope.
Defendant moved for a civil contempt finding and sanctions (including attorney’s fees) for filing in violation of the injunction.
The Bankruptcy Court denied reconsideration and found the 1996 injunction remains in effect; it awarded defendant attorney’s fees as a sanction and directed submission of a fee bill.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Enforceability of the 1996 injunction	Withdrawal of the reference in related district-court matters nullified or stripped this Court of power to enforce the injunction	The 1996 injunction remains a valid, final court order and must be obeyed	Injunction remains in effect and controls; Plaintiff’s argument rejected
Sanctions / civil contempt for filing without leave	Plaintiff suggested sanctions framework or payment interpreted the injunction’s scope and contested sanction imposition	Filing without leave violated the injunction; defendant sought attorney’s fees and other relief for contempt	Court found violation and exercised discretion to award defendant attorney’s fees; directed submission of fee bill

In re Carroll, 851 F.3d 811 (5th Cir. 2017) (discussing factors and district-court discretion for imposing injunctions and sanctions)
F.D.I.C. v. LeGrand, 43 F.3d 163 (5th Cir. 1995) (elements required to prove civil contempt)
W.R. Grace & Co. v. Local Union 759, 461 U.S. 757 (1983) (final orders and the obligation to obey them)