Granny Goose Foods, Inc. v. Teamsters
Granny Goose Foods, Inc. v. Teamsters, 415 U.S. 423, 445, 94 S.Ct. 1113, 39 L.Ed.2d 435 (1974) involved an ex parte temporary restraining order, such that, unlike EchoStar, the defendants were not involved in the proceedings leading to the issuance of the order. Moreover, the Supreme Court considered only the duration of the order, not whether any terms in the order were so vague as to make it unenforceable. Granny Goose, 415 U.S. at 445, 94 S.Ct. 1113 ("There being no order to violate, the District Court erred in holding the Union in contempt.").
In Granny Goose, the district court issued a temporary restraining order without specifying an expiration date. 415 U.S. at 428, 94 S.Ct. 1113.
Under the rule in effect at the time, the order would expire no later than twenty days after issuance. Id. at 432-33, 94 S.Ct. 1113. Prior to its expiration, the district court denied a motion to dissolve the order. Id. at 429, 94 S.Ct. 1113.
After twenty days, the district court held the union in contempt for violation of the order. Id. at 425-26, 94 S.Ct. 1113.
The union argued that contempt was improper because the order had expired before the date of the alleged contempt, id. at 430, 94 S.Ct. 1113, but the district court rejected this argument on the ground that its denial of the motion to dissolve had "effectively converted the order into a preliminary injunction of unlimited duration," id. at 440, 94 S.Ct. 1113.
The Supreme Court reversed the contempt finding, holding that "where a court intends to supplant such an order with a preliminary injunction of unlimited duration..., it should issue an order clearly saying so." Id. at 444-45, 94 S.Ct. 1113. "And where it has not done so, a party against whom a temporary restraining order has issued may reasonably assume that the order has expired within the time limits imposed by Rule 65(b)." Id. at 445, 94 S.Ct. 1113.
The Court noted that the "basic principle built into Federal Rules of Civil Procedure Rule 65 is that those against whom an injunction is issued should receive fair and precisely drawn notice of what the injunction actually prohibits." Id. at 444, 94 S.Ct. 1113.