Sheehan v. Starbucks Corp.

── Sheehan v. Starbucks Corp. ── Case No.: 25-189 Court: Court of Appeals for the Second Circuit Date: March 17, 2026 Category: General 25-189 Sheehan v. Starbucks Corp. UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL. At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 17th day of March, two thousand twenty-six. PRESENT: REENA RAGGI, ALISON J. NATHAN, Circuit Judges, JESSE M. FURMAN, District Judge.* _____________________________________ Spencer Sheehan, Sheehan and Associates, P.C., Respondents-Appellants, Kristie Brownell, individually and on behalf of all others similarly situated, Plaintiff, * Judge Jesse M. Furman, of the United States District Court for the Southern District of New York, sitting by designation.  v. No. 25-189 Starbucks Corporation, Defendant-Appellee. _____________________________________ FOR RESPONDENT-APPELLANT: Daniel R. Rose, Costello, Cooney & Fearon, PLLC, Syracuse, NY. Appeal from a judgment of the United States District Court for the Northern District of New York (Scullin, J.). UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the judgment of the district court is REVERSED. Respondents-Appellants Spencer Sheehan and his law firm appeal from a November 30, 2023 order of the United States District Court for the Northern District of New York (Scullin, J.) holding Sheehan in civil contempt, and a January 2, 2025 order of that court directing him to pay $500 as a sanction for violating Federal Rule of Civil Procedure 11(b). Sheehan argues that he violated no court orders that could form the basis for a contempt sanction, and that Rule 11 sanctions 2 were unwarranted because he did not act in bad faith. We agree and therefore reverse. We assume the parties’ familiarity with the underlying facts, procedural history, and issues on appeal, to which we refer only as necessary to explain our decision. I. Contempt We begin with the November 30, 2023 contempt order. “[B]ecause the power of a district court to impose contempt liability is carefully limited, our review of a contempt order for abuse-of-discretion is more rigorous than would be the case in other situations in which abuse of discretion review is conducted.” CBS Broad. Inc. v. FilmOn.com, Inc., 814 F.3d 91, 98 (2d Cir. 2016) (quotation marks omitted). “A court may hold a party in contempt if (1) the order the party failed to comply with is clear and unambiguous, (2) the proof of noncompliance is clear and convincing, and (3) the party has not diligently attempted to comply in a reasonable manner.” Id. (emphasis added). Civil contempt may be imposed “to secure future compliance with court orders and to compensate the party that has been wronged,” but not “as a purely punitive measure.” Paramedics 3 Electromedicina Comercial, Ltda v. GE Med. Sys. Info. Techs., Inc., 369 F.3d 645, 657 (2d Cir. 2004). A civil contempt order t