Paisley Park Enterprises, Inc. v. Boxill

Background

The court previously held Sidebar Legal, PC and its sole owner, officer, and agent, Matthew Wilson, in civil contempt for failing to comply with a March 4, 2019 order. The court directed that an arrest warrant issue for Wilson but stayed its execution to give Sidebar Legal and Wilson an opportunity to purge, or end, the contempt by complying with the order. On February 7, 2020, the court directed the United States Marshals Service to execute the warrant based on Wilson’s disregard of the court’s orders and failure to take action to purge the contempt.

In March 2020, Wilson told the court and the plaintiffs that he would comply. Sidebar Legal then produced numerous documents, while the parties engaged in settlement discussions and the magistrate judge held telephone conferences. After a hearing concerning the sufficiency of Sidebar Legal’s response, Sidebar Legal filed its motion to purge the contempt. It argued that it had produced all responsive documents or had explained why records were not produced to counsel.

Parties’ Positions

Sidebar Legal also maintained that the plaintiffs’ counsel had indicated the plaintiffs would not oppose the motion and the related arrest warrant if a settlement agreement were executed. The plaintiffs opposed the motion, stating that their position was conditional on executing a settlement agreement and that no such agreement had been executed. The plaintiffs also requested additional sanctions for alleged spoliation, meaning the destruction or loss of relevant evidence.

Ruling

The court denied Sidebar Legal’s motion. It found that the motion largely duplicated submissions already under consideration by the magistrate judge and that Sidebar Legal had not complied with the local rule requiring the parties to meet and confer before filing the motion. The court also stated that Sidebar Legal was not represented and that a corporation cannot proceed without licensed counsel in federal court.

Judge Wilhelmina M. Wright declined to consider the plaintiffs’ request for additional sanctions because the magistrate judge’s forthcoming order on that request was pending. The final order states that Sidebar Legal, PC’s Motion to Purge Civil Contempt was denied.