1. What is the standard for judging allegations of
civil contempt of an injunction or other disputed order,
as distinct from a consent de cree? Is it the same "four
corners" standard that governs a claim of contempt forallegedly violating a consen t decree – as the First and
Second Circuits both have held, and the Fourth andSeventh Circuits essentially agree? See United States
v. Armour & Co. , 402 U.S. 673, 682 (1971). Or, is the
Fifth Circuit correct in holding that a district court isentitled to "flexibility" when interpreting "reasonablyunderstood terms" that are not expressed in the actual
terms of the order itself, to vindicate the unexpressedpurposes of the same judge who rendered the order?

This Court has never squarely extended Armour to
non-consent orders or explicitly overruled the holding
in McComb v. Jackonville Paper Co. , 336 U.S. 187
(1949), that "[i]t does not lie in their mouths to say thatthey have an immunity from civil contempt because theplan or scheme which they adopted was not specificallyenjoined." Id. at 192. The Federal Circuit, en banc,
has held McComb remains binding.

2. What is the standard of appellate review of a
district court's interpretation of its own non-consentorder when imposing civil contempt sanctions?
The Fifth Circuit here performed an "abuse of
discretion" review of the applicability of an interpleaderdischarge and injunction order to the undisputedconduct of the alleged contemno r. Pet. App. 2-3. Other
Fifth Circuit decisions, as well as decisions in theSecond, Ninth and Federal Circuits, have called this "aquestion of law" to be reviewed " de novo ."

3. Can interpleader be allowed, when the allegedly
adverse creditor-claimants are asserting different debts
allegedly owed by an interpleading plaintiff? If so, doesthe interpleader remedy protect the debtor-plaintifffrom defending or paying independent liabilities thatexceed the "stake" it put forward in the action forinterpleader?
The Fifth Circuit here held interpleader is proper,
even though the creditor-claimants in the action wereclaiming different debts allegedly owed. See Pet. App.
70-71 & n.9. The traditional rule of equity, whichremains in the Second, Third and Ninth Circuits, holdsthat interpleader prevents multiple recoveries onlywhere there are not multiple obligations. The districtcourt nevertheless enforced the interpleader injunctionbeyond the deposited stake, and the Fifth Circuitaffirmed.

What is the standard for judging allegations of civil contempt of an injunction or other disputed order, as distinct from a consent decree?