Courts possess the inherent power to enforce their own orders through contempt proceedings. In re Gabbai, 968 S.W.2d 929, 931 (Tex. 1998). While on appeal, the appellate court has exclusive jurisdiction to enforce the orders at issue in the appeal, regardless of whether contempt occurred before or after the appellate court acquired jurisdiction.
Generally speaking, with a few exceptions not applicable here, courts "lack the authority to enforce another court's order by contempt." In re Gabbai, 968 S.W.2d 929, 931 (Tex. 1998) (stating that transferee courts generally lack "authority to punish by contempt acts which were committed before the transfer"); see Hereweareagain, Inc. v. City of Houston, 383 S.W.3d 703, 709 (Tex. App.—Houston [14th Dist.] Sept. 25, 2012, no pet.) (explaining that trial court has "inherent power" to enforce its own judgment through contempt proceeding); Galtex Prop. Investors, Inc. v. City of Galveston, 113 S.W.3d 922, 927 (Tex. App.—Houston [14th Dist.] 2003, no pet.) (same). But see Ex parte Barnett, 600 S.W.2d 252, 255-56 (Tex. 1980) (orig.
Our July 1996 contempt judgment was rendered after we affirmed the first of the 1995 turnover orders and while the second was on appeal. See In re Gabbai, 968 S.W.2d 929, 931 (Tex. 1998) (orig. proceeding) (holding that appellate court has exclusive jurisdiction to enforce orders being appealed, regardless of whether contempt occurred before or after appellate court acquired jurisdiction). Our 1996 contempt judgment did not make the coercive fine payable to Lobingier, and the Cadles assert the trial court erred by rendering judgment that the fine was payable to Lobingier rather than the sovereign.
And, although orders entered by a state court prior to removal become orders of this Court once a case is removed, see 28 U.S.C. § 1450, the TRO that Plaintiff seeks to enforce by contempt or sanctions was not entered in this action, and Plaintiff “has not provided any legal basis for this court to hold [Defendant] in contempt of another court's injunction, ” Carrillo v. Bank of Am., N.A., No. CIV.A. H-12-3096, 2013 WL 1558320, at *1 n.1 (S.D. Tex. Apr. 11, 2013); cf. In re Gabbai, 968 S.W.2d 929, 931 (Tex. 1998) (“While courts possess inherent power to enforce their own orders through contempt proceedings, they generally lack the authority to enforce another court's orders by contempt.
Id. 968 S.W.2d 929, 931 (Tex. 1998) (citing Ex parte Werblud, 536 S.W.2d 542, 544 (Tex. 1976), and Ex parte Travis, 123 Tex. 480, 73 S.W.2d 487, 488-89 (1934)).Id.
We also explained "[t]here can be no doubt that parties are required to comply with this Court's orders" and that "this Court has exclusive jurisdiction to enforce its orders-which it must do. See In re Gabbai, 968 S.W.2d 929, 931 (Tex. 1998); see also Tex. R. App. P. 42.3(c)."
Moreover, this Court has exclusive jurisdiction to enforce its orders-which it must do. See In re Gabbai, 968 S.W.2d 929, 931 (Tex. 1998); see also Tex. R. App. P. 42.3(c).
Moreover, this Court has exclusive jurisdiction to enforce its orders-which it must do. See In re Gabbai, 968 S.W.2d 929, 931 (Tex. 1998); see also Tex. R. App. P. 42.3(c).
Courts possess the inherent power to enforce their own orders through contempt proceedings. See In re Gabbai, 968 S.W.2d 929, 931 (Tex. 1998). This includes the power to hold a party in contempt for violating a temporary injunction issued by the court.
If the trial court finds more than one act of contempt but assesses only one punishment, and if one act is not punishable by contempt, then the entire judgment is void. In re Hall , 433 S.W.3d 203, 207 (Tex. App.—Houston [14th Dist.] 2014, orig. proceeding) (citing In re Henry , 154 S.W.3d 594, 598 (Tex. 2005) (orig. proceeding), and In re Gabbai , 968 S.W.2d 929, 931 (Tex. 1998) (orig. proceeding) ). In contrast, if the trial court assesses a separate punishment for each act of contempt, only the invalid portions are void.