Due Process At Work In This One.
In In re Icenhower, Case No. 12-56329 (9th Cir. June 26, 2014) (published), a bankruptcy court imposed contempt sanctions against defendants for failing to transfer a Mexican coastal villa to plaintiff. The district court, however, vacated $25,000 daily sanctions for failure to vacate on the basis that the defense had not been given clear notice that sanctions would be imposed for earlier points in time before a certain date where sanctions were known to fall on the defense. The Ninth Circuit agreed, on due process grounds.