Continuing a series of opinions that vacated findings of contempt – most recently in Waste Management v. Kattler, 776 F.3d 336 (5th Cir. 2015) – the Fifth Circuit vacated a contempt finding against an attorney for allegedly encouraging his client to make inappropriate online postings. Test Masters Educational Services v. Singh Educational Services, No. 13-20250 (Aug. 21, 2015). Applying Waste Management, the Court found inadequate notice from a show-cause order that only named the client. On the merits, agreeing that the relevant injunction against the client bound the attorney, the Court found no clear and convincing evidence that he personally had violated the injunction.
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