## Facts

- Paula Corbin Jones sued William Jefferson Clinton and Danny Ferguson for damages arising from an alleged May 8, 1991 sexual-harassment incident while Clinton was Governor of Arkansas.
- The case proceeded through discovery; the court entered orders permitting and requiring discovery into Clinton’s sexual relationships with subordinate government employees as potentially relevant.
- On January 17, 1998, Clinton testified under oath at a deposition conducted under the district judge’s supervision and denied having “sexual relations” with Monica Lewinsky and denied recollection of being alone with her.
- After later public admissions and evidence contradicted those denials, the district court addressed whether Clinton’s discovery responses violated the court’s orders.
- The underlying civil action had been dismissed on summary judgment; while an appeal was pending, the parties settled and the appeal was dismissed.
- The court initiated post-judgment proceedings to determine whether Clinton should be held in civil contempt for his discovery conduct.

## Issues

1. Whether Clinton willfully violated specific and definite discovery orders by giving false, misleading, and evasive deposition testimony about his relationship with Monica Lewinsky.
2. Whether such conduct warranted a civil contempt finding and remedial sanctions under the court’s authority and Federal Rule of Civil Procedure 37.

## Decision

- The court adjudged Clinton in civil contempt for willful failure to obey its discovery orders.
- The court found Clinton had knowledge of the discovery orders and that the orders encompassed the subject matter about which he provided deceptive testimony.
- The court concluded his deposition answers were false, misleading, and evasive, and were intended to obstruct the judicial process.
- The court imposed remedial sanctions, including payment of reasonable expenses and attorney’s fees caused by the contempt.
- The court directed that the matter be referred to appropriate professional disciplinary authorities for potential attorney discipline.

## Legal Principles

- Civil contempt may be found when a party violates a specific and definite court order with knowledge of the order, and the violation is not justified by a good-faith, reasonable interpretation of the order.
- Discovery orders requiring responsive testimony obligate truthful, complete answers within the authorized scope; deliberate deception in discovery can constitute contempt.
- Civil contempt sanctions may be remedial, including compensatory awards of costs and attorney’s fees attributable to the contemptuous conduct.
- Courts may use their inherent authority and Rule 37 to address discovery abuses that interfere with the fair administration of justice.

## Conclusion

The district court held that Clinton’s knowing, deceptive deposition testimony on matters covered by court-ordered discovery constituted a willful violation of discovery orders, warranting civil contempt, compensatory monetary sanctions, and referral to attorney disciplinary authorities.


Jones v. Clinton, 36 F. Supp. 2d 1118 (E.D. Ark. 1999)