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United States v. Professional Air Traffic Controllers Organization

Court of Appeals for the First Circuit
678 F.2d 1 (1982)
ELI5:

Rule of Law:

A fixed, unconditional fine imposed for a past violation of a court order is a punitive sanction that can only be levied in a criminal contempt proceeding, not a civil one. Furthermore, an injunctive order is not unconstitutionally vague if it uses a term, such as 'picket,' whose meaning is commonly understood by persons of common intelligence, particularly those to whom the order is directed.


Facts:

  • Robert Belanger was the President of Local 202 of the Professional Air Traffic Controllers Organization (PATCO), which was engaged in a nationwide strike against the Federal Aviation Administration (FAA).
  • On September 7, 1981, Belanger was present with a crowd of 200-300 people at the entrance to an FAA Center, where the crowd shouted epithets and interfered with vehicles.
  • On September 19, Belanger mingled with a crowd of about 100 people at the same location and led strike-related cheering through a megaphone as working employees were insulted.
  • On October 4, a police officer warned Belanger that his actions could lead to his arrest for violating a court injunction.
  • Following the warning, Belanger replied that the officer should "do what you want to do [and] I will do what I have to do."
  • Belanger then proceeded to patrol back and forth with 20-25 other PATCO members within 5 to 7 feet of the FAA Center's gate.

Procedural Posture:

  • The United States (appellee) obtained a temporary restraining order in the U.S. District Court for the District of New Hampshire against strike-related activities by PATCO Local 202.
  • The District Court later issued a preliminary injunction limiting picketing activities, which was personally served on Robert Belanger (appellant).
  • The government petitioned the District Court to hold Belanger in contempt for violating the preliminary injunction.
  • After a hearing, the District Court found Belanger in civil contempt and imposed a $5,000 fine.
  • Belanger appealed the contempt finding and the fine to the U.S. Court of Appeals for the First Circuit.

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Issue:

Is an unconditional, fixed monetary fine imposed for past violation of a court order a permissible sanction in a civil contempt proceeding?


Opinions:

Majority - Torruella, District Judge

No. An unconditional, fixed fine for past conduct is punitive, not remedial, and is therefore impermissible as a sanction in a civil contempt proceeding. Civil contempt sanctions must be wholly remedial, meaning they are either coercive (to compel future compliance) or compensatory (to reimburse the complainant for actual losses). The government sought the fine to punish Belanger for his past willful disobedience, not to compensate for any proven loss or to coerce future compliance. A definite fine that is neither compensatory nor conditioned on future violations is punitive and can only be imposed in a criminal contempt proceeding, which requires constitutional safeguards such as notice of the criminal charge and proof beyond a reasonable doubt, none of which were afforded here.



Analysis:

This decision reinforces the fundamental distinction between civil and criminal contempt by focusing on the purpose of the sanction. It prevents courts from using the procedurally simpler civil contempt process to impose punitive sanctions that are reserved for criminal proceedings. This holding ensures that individuals facing punitive fines for past disobedience of court orders are afforded the higher constitutional protections required in criminal cases, such as the right to a jury trial for serious offenses and the 'beyond a reasonable doubt' standard of proof. The case also clarifies that the 'void for vagueness' doctrine does not require an injunction to define terms whose meanings are well-understood in the relevant context.

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