Waste Management of Washington, Inc. v. Kattler

PRISCILLA R. OWEN, Circuit Judge.

This appeal arises from a contempt proceeding ancillary to the merits of the underlying case. Michael A. Moore, the attorney for Dean Kattler, the defendant in the proceedings below, appeals the imposi tion of sanctions following a finding that Moore was in civil contempt. Moore contends that he was not afforded procedural due process and that the district court abused its discretion by finding him in contempt. We vacate the contempt finding and sanctions.

I

In the underlying litigation, Waste Management, Inc. (WM) sued Kattler, a former employee, for…