because there was no harm requiring compensation — the Receiver would have prepared for and attended the show cause hearing even if Solera had shown up. In fact, that hearing would have taken longer and would have cost more if Solera had shown up. Because that part of the sanction award was neither coercive nor compensatory, it was punitive in nature. See id. (“[T]he sanctions imposed by the district court were neither compensatory nor coercive in nature, but instead were designed to punish [the contemnor] for flouting the authority of the district court”). A “district court may not use the civil contempt power to impose what amounts to a punitive or criminal contempt sanction.” United States v. City of Miami, 195 F.3d 1292, 1298 (11th Cir.1999); see also DuPont, 99 F.3d at 369 (<HOLDING>). Because the district court imposed what
holding that the imposition of sanctions is reviewed for abuse of discretion holding that the district court committed reversible error by imposing criminal sanctions in a civil proceeding which did not afford the contemnor the procedural protections the constitution requires for the imposition of criminal contempt sanctions holding that trial court erred by imposing sanctions against attorney without notice and hearing but error was cured by attorneys subsequent challenge to sanctions holding that an individual charged with criminal contempt is entitled to the full procedural protections afforded the defendant in any other criminal proceeding holding that 25 surcharge added to fees that otherwise would be compensatory was a criminal contempt sanction even though it was payable to the adverse party and not to the court reversing order for sanctions because court did not follow procedural requirements for criminal contempt