Chevron Corp. v. Donziger, No. 18-855 (2d Cir. 2021)
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Defendant appealed the district court's amended judgment awarding costs to Chevron under Federal Rule of Civil Procedure 54(d), several interlocutory orders declining to dismiss civil contempt proceedings against him and ordering compliance with post-judgment discovery, and a judgment and order finding him in civil contempt.
The Second Circuit concluded that the district court did not err in awarding costs to Chevron. The court also affirmed the district court's finding that defendant violated the Injunction in several respects and its judgment of civil contempt relating to those violations. However, the court held that the Injunction, previously affirmed by this Court and clear and far-reaching on its own terms, was insufficiently clear and unambiguous, when read alongside the district court's explanation of that Injunction in a subsequent opinion, in prohibiting defendant from raising funds by selling interests in the Ecuadorian Judgment. Thus, the court concluded that the district court erred in finding defendant in contempt for engaging in that conduct. Accordingly, the court affirmed the district court's amended judgment awarding costs to Chevron; affirmed in part and reversed in part the district court's contempt finding and vacated the supplemental judgment awarding Chevron $666,476.34 in compensatory sanctions; and vacated the supplemental judgment awarding attorneys' fees and remanded to the district court to determine the fees reasonably expended to secure the contempt findings affirmed on appeal.
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