H.K. Development, LLC. v. Greer

We have for review an Order to Compel and an Order of Contempt. Both orders impose monetary fines: Discrete discovery violations were committed in the course of a judgment creditor’s efforts to enforce a consent judgment against appellants. We reverse both orders insofar as they retrospectively 1 impose sanctions payable to the judgment creditor — absent evidence of the amount of damages occasioned by the sanctioned conduct — and remand for further proceedings.

On April 30, 2007, after entry of consent judgment in his favor, Michael D. Greer secured an ex parte order requiring all appellants…