U.S. Securities and Exchange Commission v. Hyatt

Dist. Ct. erred in holding individual and entity in contempt for failing to adequately respond to two subpoenas served on them by SEC in connection with litigation between SEC and another party. While said individuals failed to appear at initial hearing when contempt sanction was imposed, instant contempt order was improper where SEC notice and motion for rule to show cause did not provide individual and entity with sufficient notice that Dist. Ct. would decide contempt issue at initial hearing, given fact that said notice only sought issuance of show cause order and asked Dist. Ct. to set future hearing on merits of contempt issue. Fact that entity had argued merits of contempt issue at initial hearing in different case pursuant to similar notice given by SEC did not require different result.