What is the effect of a contempt order against the trustees of a trustee in a personal injury case?

The contempt order satisfied several of the well-established criteria for finality of a civil contempt order, but lacked one essential factor. Two requirements were present: the order against the trustees followed the final judgment on the merits, and the appeal was taken together with the appeal from the final judgment. See Shuffler v. United States, 720 F.2d 1141, 1145 (9th Cir.1983). Compare Hughes v. Sharp, 476 F.2d 975 (9th Cir.1973) (civil contempt order remains interlocutory if against party during proceedings). Sanctions had not yet been imposed, however.

The requirement of a sanction to render a contempt order final under section 1291 is expressed in Alexander v. United States, 201 U.S. 117, 121-22, 26 S.Ct. 356, 357-58, 50 L.Ed. 686 (1906):

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