Seventh Circuit Questions Standard of Review for Orders Declining to Exercise Ancillary Enforcement Jurisdiction

In Continental Indem. Co. v. BII, Inc., N. 23-1648 (7th Cir. June 12, 2024), the Seventh Circuit affirms dismissal of an action filed under Fed. R. Civ. P. 69 by an insurer against an alleged garnishee, holding that it fell outside the court’s ancillary enforcement jurisdiction. The panel, though, reserves for future consideration whether theContinue reading “Seventh Circuit Questions Standard of Review for Orders Declining to Exercise Ancillary Enforcement Jurisdiction”

District Court Had Ancillary Enforcement Jurisdiction to Enforce Attorney’s Lien in Post-Judgment Proceeding, Holds First Circuit

In Butt v. United Brotherhood, No. 18-2272 (3d Cir. June 8, 2021), the First Circuit holds that the district court maintained subject matter jurisdiction to adjudicate a fee dispute between a pair of lawyers who represented three women in an employment discrimination lawsuit. Attorney Paddick represented plaintiffs (the Clients) on a 40% contingency fee throughContinue reading “District Court Had Ancillary Enforcement Jurisdiction to Enforce Attorney’s Lien in Post-Judgment Proceeding, Holds First Circuit”

Fifth Circuit Holds That District Court Has “Ancillary Enforcement Jurisdiction” To Decide Belated Fee Petition, Then Affirms Denial of Fees

In Zimmerman v. City of Austin, Texas, No. 19-50857 (5th Cir. Aug. 13, 2020) , the plaintiff who won a partial victory in a First Amendment trial failed to file a timely attorney’s fee petition under  42 U.S.C. § 1988(d), either for the trial or the direct appeal (881 F.3d 378 (5th Cir. 2018)) affirmingContinue reading “Fifth Circuit Holds That District Court Has “Ancillary Enforcement Jurisdiction” To Decide Belated Fee Petition, Then Affirms Denial of Fees”