In Havens v. James, No.20-664_(2d Cir. Aug. 4, 2023), a split Second Circuit panel holds that under Fed. R. Civ. R. 65(d)(2), that for a non-party to be subject to an injunction as acting in “active concert or participation,” they must act with the purpose of benefiting or assisting an enjoined party. The panel majorityContinue reading “Split Second Circuit Panel Holds That A Non-Party Is In “Active Concert or Participation” Under Fed. R. Civ. P. 65(d) Only If They Intend to Benefit or Assist an Enjoined Party”
