What is the standard for judging allegations of civil contempt of an injunction or other disputed order, as distinct from a consent decree?

QUESTIONS PRESENTED 1. What is the standard for judging allegations of civil contempt of an injunction or other disputed order, as distinct from a consent decree? Is it the same “four corners” standard that governs a claim of contempt for allegedly violating a consent decree — as the First and Second Circuits both have held, and the Fourth and Seventh Circuits essentially agree? See United States v. Armour & Co., 402 U.S. 673, 682 (1971). Or, is the Fifth Circuit correct in holding that a district court is entitled to “flexibility” when interpreting “reasonably understood terms” that are not expressed in the actual terms of the order itself, to vindicate the unexpressed purposes of the same judge who rendered the order? This Court has never squarely extended Armour to non-consent orders or explicitly overruled the holding in McComb v. Jackonville Paper Co., 336 U.S. 187 (1949), that “[i]t does not lie in their mouths to say that they have an immunity from civil contempt because the plan or scheme which they adopted was not specifically enjoined.” Jd. at 192. The Federal Circuit, en banc, has held McComb remains binding. 2. What is the standard of appellate review of a district court’s interpretation of its own non-consent order when imposing civil contempt sanctions? The Fifth Circuit here performed an “abuse of discretion” review of the applicability of an interpleader discharge and injunction order to the undisputed conduct of the alleged contemnor. Pet. App. 2-3. Other Fifth Circuit decisions, as well as decisions in the Second, Ninth and Federal Circuits, have called this “a question of law” to be reviewed “de novo.” ll 3. Can interpleader be allowed, when the allegedly adverse creditor-claimants are asserting different debts allegedly owed by an interpleading plaintiff? Ifso, does the interpleader remedy protect the debtor-plaintiff from defending or paying independent liabilities that exceed the “stake” it put forward in the action for interpleader? The Fifth Circuit here held interpleader is proper, even though the creditor-claimants in the action were claiming different debts allegedly owed. See Pet. App. 70-71 & n.9. The traditional rule of equity, which remains in the Second, Third and Ninth Circuits, holds that interpleader prevents multiple recoveries only where there are not multiple obligations. The district court nevertheless enforced the interpleader injunction beyond the deposited stake, and the Fifth Circuit affirmed.