## Facts

- In Pennsylvania divorce and equitable-distribution proceedings, a state court ordered H. Beatty Chadwick to place about $2.5 million of marital funds into a court-controlled escrow account.
- Chadwick had transferred marital assets through entities and accounts outside the court’s reach; the court found the transfers fraudulent and intended to defeat the court’s authority and his spouse’s claims.
- The court ordered Chadwick to repatriate the funds, pay attorney’s fees, surrender his passport, and remain within the court’s jurisdiction.
- Chadwick refused to comply and failed to appear personally at multiple contempt hearings; state courts repeatedly found he had the present ability to comply.
- Chadwick was arrested on April 5, 1995, while attempting to flee and was jailed for civil contempt until he complied with the escrow directive or posted a $3 million bond.
- After nearly seven years of confinement, Chadwick filed a federal habeas petition under 28 U.S.C. § 2254; the district court deemed state remedies exhausted and ordered his release on the ground that confinement had become punitive rather than coercive.
- State officials and Chadwick’s ex-wife appealed.

## Issues

1. Whether a § 2254 petitioner exhausts state remedies without seeking discretionary review in the state supreme court from an adverse intermediate-appellate decision, when he later files an original-jurisdiction habeas petition in the state supreme court.
2. Whether lengthy civil-contempt confinement violates due process when state courts continue to find the contemnor has the present ability to comply with the purge condition.

## Decision

- The Third Circuit reversed the district court’s grant of habeas relief.
- The court held Chadwick failed to exhaust state remedies because he did not complete a full round of the state’s established appellate review process.
- The court further held that the district court erred on the merits: duration alone did not convert the confinement into unconstitutional punishment where Chadwick retained the ability to comply.

## Legal Principles

- A § 2254 petitioner must give state courts one full opportunity to resolve federal claims by invoking one complete round of the state’s established appellate review process; an original-jurisdiction state habeas filing does not automatically substitute for omitted discretionary appellate review.
- Civil contempt confinement is coercive, not punitive, when the contemnor can secure release by complying with the court order (the contemnor “holds the keys” to release).
- The length of civil-contempt incarceration, standing alone, does not make the confinement unconstitutional if state courts continue to find present ability to comply and the contemnor has not shown impossibility.
- Federal habeas review must defer to state-court factual findings on present ability to comply absent a valid basis to disregard them under § 2254 standards.

## Conclusion

The Third Circuit reversed habeas relief, concluding that Chadwick had not exhausted state remedies and that his continued civil-contempt confinement remained constitutionally permissible because he could purge the contempt by complying with the escrow order.


Chadwick v. Janecka, 312 F.3d 597 (3d Cir. 2002)