In U.S. v. Straub, No. 06-14354 (Nov. 29, 2007), the Court affirmed the criminal contempt conviction of a defendant who violated a court order to not be present during the removal of property from specific premises.
The defendant claimed that the district court lacked jurisdiction to hold him in criminal contempt, because the court later determined that it lacked subject matter jurisdiction over the case. Rejecting this argument, the Court analogized criminal contempt to sanctions under Rule 11 of the Federal Rules of Civil Procedure – which can be imposed regardless of whether a court lacks subject matter jurisdiction. Willy v. Coastal Corp., 503 U.S. 131 (1992). The Court distinguished contrary dicta in its caselaw as "inapposite."
The Court also concluded that the order that Straub was charged with violating was "reasonably specific," and further rejected Straub’s claim that his conduct was not "willful."