Edwards v. Pekin Memorial Hospital

The attorney for plaintiff appealed from a contempt order directing him to pay attorney fees to counsel for defendant after the circuit court found him in indirect civil contempt for inadvertently disclosing confidential information in violation of a court order incorporating a confidentiality agreement binding the parties and their respective attorneys. Defendant cross-appealed, arguing that the trial court erred when it found the disclosure inadvertent. The appellate court reversed the contempt finding, vacated the attorney fee award, and dismissed the cross-appeal as moot, finding that because the disclosure could not be undone, there was no rationale for an entry of civil contempt because it could only serve to prevent future disclosures, not to correct a disclosure that had already been made. (BRENNAN and HETTEL, concurring)