M.D. v. Abbott

(1) Whether civil contempt sanctions imposed through proceedings that undisputedly comported with civil due process may be affirmed even if the contempt order seemingly also imposed punitive sanctions; (2) whether the defense of “substantial compliance” involves more than a mathematical inquiry and instead requires alleged civil contemnors to show they took “all reasonable steps” to comply with the clear intent of pertinent court orders; and (3) whether a court of appeals should consider whether opinions expressed by a district judge were properly formed during the course of litigation and should give significant weight to the resulting waste and duplication of judicial effort before taking the extraordinary step of removing a diligent district judge from a complex case.