SonCo Holdings, LLC v. Bradley

Dist. Ct. did not err in finding that intervenor was in contempt for failing to abide by prior settlement order that directed intervenor to obtain $250,000 bond to assure payment to Texas Railroad Commission of any costs it might impose on operator of certain oil wells, as well as obtain authorization by said Commission to operate said oil wells. However, Dist. Ct. erred in imposing sanction that allowed receiver to keep $600,000 that intervenor had previously paid for leases on said oil wells, where Dist. Ct. had failed to explain how $600,000 sanction was related to receiver's costs incurred as result of intervenor's misconduct. On remand, Dist. Ct. must either re-impose instant sanction and provide explanation for compensatory basis for said sanction, or impose different sanction amount, or proceed under rules governing criminal contempt that allow for issuance of punitive sanctions.