Doral Produce Corp., Plaintiff-Counter-Defendant-Appellee v. Paul Steinberg Assoc., Inc., Defendant-Counter-Claimant, Mark C.H. Mandell

LEVAL and KATZMANN, Circuit Judges.

The appellant, Mark Mandell, Esq., an attorney who represented defendant Paul Steinberg Associates, Inc. in a nonjury trial conducted in the United States District Court for the Southern District of New York (Motley, J.), appeals from the district court’s ruling, summarily holding him in contempt and imposing a fine of $500, for asking a question which the court believed to be in contravention of its rulings.

We reverse the contempt conviction, for two reasons, one substantive, the other procedural. First, because willfulness is an essential element of…