## Facts

- The United States sued the City of Yonkers and its Community Development Agency, and a federal court found them liable for intentionally increasing housing segregation in violation of the Fair Housing Act and the Fourteenth Amendment.
- The district court entered remedial orders requiring affirmative steps to disperse public housing and later approved a consent judgment requiring the city council to adopt an Affordable Housing Ordinance within a set time.
- After continued delay, the district court ordered that failure to enact the ordinance would result in escalating daily fines against the City and, for individual councilmembers, daily fines and imprisonment if they did not vote in favor of the ordinance.
- The city council defeated a resolution of intent to adopt the ordinance by a 4–3 vote; the petitioning councilmembers were in the majority.
- The district court held the City and the individual councilmembers in contempt and imposed the previously specified sanctions.
- The court of appeals affirmed the sanctions against the councilmembers.
- The Supreme Court stayed sanctions against the individual councilmembers but not against the City; under mounting daily fines, the council enacted the ordinance.

## Issues

1. Whether a district court, applying traditional equitable principles, abuses its discretion by imposing coercive contempt sanctions on individual city councilmembers (who were not parties and were not found individually liable) to compel affirmative votes on legislation when sanctions against the municipality had not been exhausted.

## Decision

- The Supreme Court reversed the judgment insofar as it upheld contempt sanctions against the individual councilmembers.
- The Court held that, in these circumstances, coercive sanctions conditioned on how individual legislators voted were an abuse of discretion under traditional equitable principles.
- The Court emphasized that the primary remedial obligations ran against the City, and that effective, escalating municipal fines were available and ultimately proved sufficient to secure compliance.
- The Court declined to rest its decision on a broad First Amendment holding, resolving the case on equitable limits and the sequencing of coercive remedies.

## Legal Principles

- Civil contempt enforcement of institutional remedies must be guided by traditional equitable discretion, including selecting the least intrusive effective means to obtain compliance.
- When a remedial obligation is directed to a governmental entity, courts should generally pursue and exhaust effective sanctions against the entity before imposing coercive contempt sanctions on individual legislators.
- Coercive sanctions that condition personal penalties on the content of a legislator’s vote warrant special caution, particularly where the legislators were not parties to the action and were not found individually liable for the underlying violation.

## Conclusion

The Court held that, given the councilmembers’ nonparty status, the absence of individual liability, and the availability of effective escalating fines against the City, it was an abuse of equitable discretion to impose personal contempt fines or imprisonment to compel particular legislative votes.


Spallone v. United States, 493 U.S. 265 (1990)