United States Catholic Conference v. Abortion Rights Mobilization, Inc. (1987)
- Docket
- 87-416
- Decided
- 1987-01-01
Summary
Question: May a nonparty witness challenge a civil contempt citation by challenging the court’s subject matter jurisdiction over the underlying lawsuit? Conclusion: Yes. Justice Anthony M. Kennedy delivered the opinion for the 8-1 majority in which the Court reversed and remanded the appellate court’s ruling. The Court held that a nonparty witness may challenge the court’s jurisdiction over the underlying lawsuit in defense of a civil contempt citation. The Second Circuit’s jurisdiction standard impermissibly expanded the reach of judicial power because it permitted a court to act in issues without an actual case or controversy, as required by Article III of the Constitution. The Court also held that, because the judiciary may impose sanctions for the abuse of court processes, restricting a nonparty’s right to appeal a civil contempt citation is unnecessary. In his dissenting opinion, Justice Thurgood Marshall stated that he agreed with the Second Circuit’s concern that allowing a witness to raise subject matter jurisdiction challenges while appealing a contempt citation invited collusion with defendants who, unlike witnesses, lack a right to appeal interlocutory orders prior to a final judgment in the action. allowing a witness to raise subject matter jurisdiction challenges while appealing a contempt citation invited collusion with defendants who, unlike witnesses, lack a right to appeal interlocutory orders prior to a final judgment in the case.