Civil Contempt for Violating No-Suit Orders, Corporate Dissolution, and Limits on Pro Se Appeals: A Commentary on Lucas v. Dadson Manufacturing Corporation, No. 25‑3074 (10th Cir. Dec. 16, 2025)

I. Introduction

This Tenth Circuit order and judgment arises out of a long‑running and increasingly contentious dispute between a former corporate executive, James R. Lucas, and his former company and family members tied to that corporation. The decision in Lucas v. Dadson Manufacturing Corporation, No. 25‑3074 (10th Cir. Dec. 16, 2025), although unpublished, provides instructive guidance on several doctrinal points:

• How federal courts enforce no‑suit agreements and orders through civil contempt sanctions, including fee‑shifting;
• The limited consequences of a corporation’s administrative dissolution under Missouri law for ongoing litigation;
• The objective reasonableness standard governing civil contempt, even where a litigant claims a good‑faith legal belief;
• The requirement that appellants—including pro se litigants—adequately brief issues on appeal; and
• The limits of appellate jurisdiction where no criminal sanction has actually been imposed, and the high bar for proving judicial bias.

The Tenth Circuit affirmed a district court order that:

1. Refused to sanction the defendants for not disclosing the corporation’s dissolution;
2. Held Lucas in civil contempt for violating a prior order not to file further related litigation, and awarded defendants substantial attorney’s fees and costs;
3. Declined to impose any criminal contempt sanction; and
4. Rejected Lucas’s claim that the district judge was biased against him.

While the opinion is designated as non‑precedential, it may be cited for its persuasive value and offers a clear, integrated application of contempt doctrine, corporate dissolution law, and appellate procedure in the context of vexatious post‑settlement litigation.

II. Factual and Procedural Background

A. The Underlying Corporate Relationship and State Court Litigation

From 2006 to 2017, James R. Lucas served as CEO and board chairman of Dadson Manufacturing Corporation (“Dadson”). During his tenure, he took deferred salary and made personal loans to Dadson. After his 2017 termination, Lucas sued in state court (Johnson County, Kansas) to recover:

• Deferred compensation; and
• Repayment of personal loans to Dadson.

The defendants—which included Dadson, the Nancy F. Peterson Trust (the corporate owner), and various individuals (Nancy Peterson, Pamela Lucas, and Peter Lucas)—counterclaimed, alleging:

• Dadson had overpaid Lucas on his loans;
• Lucas diverted corporate assets to himself and other companies; and
• He breached fiduciary duties owed to Dadson.

A jury verdict produced a mixed outcome:

• Lucas was awarded $278,066.05 in deferred salary;
• Dadson was awarded $117,328.64 for conversion of overpaid loans and $400,000 for breach of fiduciary duty; and
• Dadson was found entitled to punitive damages.

The net result was a money judgment of $239,262.59 against Lucas, with punitive damages still in play.

B. The 2019 Settlement and Releases

On March 12, 2019, the parties entered into a settlement agreement. Key terms included:

• Dadson’s agreement not to pursue punitive damages or initiate further actions against Lucas; and
• Lucas’s dismissal of his appeal and waiver of claims against:
  • Dadson;
  • The Nancy F. Peterson Trust;
  • Nancy Peterson;
  • Pamela Lucas; and
  • Peter Lucas.

Despite this comprehensive settlement and release, Lucas later filed multiple additional claims, motions, and appeals against these defendants, their counsel, and others involved in the original litigation. This history of aggressive, repetitive litigation serves as important context both for the district court’s sanctions and for the Tenth Circuit’s analysis of judicial “bias.”

C. The 2022 Federal Suit and the 2023 No‑Suit Order

On March 18, 2022, Lucas filed yet another lawsuit, this time in the U.S. District Court for the District of Kansas, naming Dadson and Peter Lucas as defendants. In light of the prior settlement and releases, the district court granted summary judgment to the defendants and entered judgment on February 15, 2023.

Defendants then moved for sanctions. At a June 5, 2023 evidentiary hearing, the parties reached a new agreement:

• Defendants would withdraw their then‑pending motion for sanctions;
• In exchange, Lucas agreed not to file any new lawsuits against:
  • Dadson;
  • Nancy Peterson;
  • The Nancy Peterson Trust;
  • Peter Lucas;
  • Pamela Lucas; or
  • Mark Bodine (defense counsel),

  if those lawsuits related to the first deferred salary/personal loan suit.

The district court memorialized this agreement in a written order on June 9, 2023. The court:

• Denied the then‑pending sanctions motion as moot (because of the agreement);
• Retained jurisdiction over the case; and
• Explicitly warned Lucas that if he violated the no‑suit order, the court would revisit sanctions, including sanctions related to past conduct.

Lucas appealed this order, and the Tenth Circuit affirmed in an earlier unpublished decision: Lucas v. Dadson Mfg. Corp., No. 23‑3124, 2024 WL 1617302 (10th Cir. Apr. 15, 2024).

D. Dadson’s Dissolution and the 2024 Missouri Suit

In June 2022—shortly after Lucas filed the 2022 federal case—Dadson was administratively dissolved in Missouri. Lucas did not discover this dissolution until late 2024.

On November 5, 2024, Lucas filed a new lawsuit in the Circuit Court of Jackson County, Missouri, against:

• Dadson;
• Peter Lucas; and
• Thomas Reppell (a former attorney for and director of Dadson).

He sought:

• $33,978.45 for alleged refusal to accept a settlement offer in the federal action;
• $167,506.61 representing his personal loans to Dadson; and
• Sanctions of $100,000 or more.

Lucas’s theory was that Missouri’s dissolution statutes—including Mo. Rev. Stat. §§ 351.476 and 351.478—required a dissolved corporation to wind up and liquidate promptly, and that Dadson’s refusal to accept his settlement offer allegedly violated these winding‑up duties.

E. The 2025 Contempt Proceedings in Federal Court

On January 24, 2025, defendants returned to the Kansas federal court and moved for an order to show cause why Lucas should not be held in civil contempt for violating the June 9, 2023 no‑suit order by filing the Jackson County, Missouri case. They requested:

• Attorney’s fees incurred in:
  • The federal action; and
  • The Jackson County litigation;
• Injunctive relief barring Lucas from filing further related actions without leave of court; and
• Denial of in forma pauperis status on appeal.

Lucas counter‑moved for an order to show cause why the defendants should not be held in contempt for supposedly misleading the court by failing to disclose Dadson’s corporate dissolution.

The district court issued show‑cause orders and held a hearing on February 28, 2025. It found:

• There was no dispute that:
  • A valid court order (the June 9, 2023 order) existed;
  • Lucas knew of the order; and
  • He violated it by filing the Jackson County case.
• The only remaining issue as to Lucas was the appropriate sanction for civil contempt.

The court:

• Awarded defendants:
  • $38,494.41 in legal fees and expenses incurred to date in the federal case and the Jackson County case; and
  • $5,280 in costs associated with the contempt hearing.
• Rejected Lucas’s request to sanction defendants, finding no misrepresentation and no duty to have disclosed Dadson’s dissolution.

Defendants also orally requested that Lucas be jailed for 24 hours. The district judge declined to consider that request because it had not been noticed in a written motion, and directed counsel to file a separate motion if they wished to pursue confinement. No such criminal contempt process was initiated.

III. Summary of the Tenth Circuit’s Decision

The Tenth Circuit affirmed in full. Its key holdings:

1. Refusal to sanction defendants: Lucas failed to present an adequate, developed argument that the district court abused its discretion in refusing to sanction defendants for not disclosing Dadson’s dissolution. Moreover, the Missouri dissolution statute (Mo. Rev. Stat. § 351.476) does not support his view that dissolution required defendants to accept his settlement demand or immediately end litigation.
2. Civil contempt sanctions against Lucas: The district court did not abuse its discretion in holding Lucas in civil contempt and awarding defendants attorney’s fees and costs. Lucas undisputedly violated a valid, known court order. His asserted belief that Missouri law justified his conduct was objectively unreasonable and therefore no defense to civil contempt.
3. Criminal sanctions not imposed: Lucas lacked standing to complain about criminal sanctions that were never actually imposed. Because the district court did not initiate criminal contempt proceedings or order punitive sanctions, there was no appealable injury.
4. Judicial bias: The record showed the district judge’s displeasure was based solely on Lucas’s litigation conduct. Under Liteky v. United States, 510 U.S. 540 (1994), such case‑driven irritation does not amount to the deep‑seated favoritism or antagonism that makes fair judgment impossible. The bias claim failed.

Together, these rulings reinforce that a litigant—even a pro se litigant—must obey court orders and cannot justify noncompliance by re‑arguing perceived legal errors; that corporate dissolution under Missouri law does not extinguish pending litigation or create a duty to settle; and that appellate courts will not correct unpreserved or under‑briefed issues.

IV. Detailed Analysis

A. Precedents and Authorities Cited

1. Missouri Corporate Dissolution: Mo. Rev. Stat. § 351.476

Lucas’s central theory—both in his Missouri lawsuit and in his appeal of the contempt order—was that Dadson’s administrative dissolution triggered an obligation to wind up and liquidate so aggressively that the company was legally required to accept his settlement demand and could not continue litigation “forever.” He invoked Mo. Rev. Stat. §§ 351.476 and 351.478.

The Tenth Circuit relied on the text of § 351.476, which expressly states that dissolution of a Missouri corporation does not:

• “[a]bate or suspend a proceeding pending by or against the corporation,” or
• “[p]revent commencement of a proceeding by or against the corporation in its corporate name.”

In other words, under Missouri law, a dissolved corporation:

• May continue to sue and be sued, and
• Ongoing proceedings are not stayed or extinguished by dissolution.

The Tenth Circuit found no statutory support—and Lucas cited none—for the proposition that a dissolved corporation must, in effect, capitulate to pending claims or terminate all active litigation as part of “winding up.”

2. Adequate Briefing and Pro Se Litigants: Garrett v. Selby Connor Maddux & Janer

To dispose of Lucas’s challenge to the denial of sanctions against defendants, the Tenth Circuit invoked Garrett v. Selby Connor Maddux & Janer, 425 F.3d 836 (10th Cir. 2005). That case stands for three related principles:

• Pro se filings are construed liberally; courts will overlook technical pleading defects.
• However, even a pro se appellant must present coherent arguments, cite some relevant authority, and meaningfully engage with the standard of review.
• Appellate courts are not advocates: they will not “construct arguments and search the record” for a litigant.

Here, Lucas:

• Accused defendants of violating Missouri corporate law and misleading the court; but
• Did not identify any court order defendants allegedly violated; and
• Did not grapple with why the district court’s refusal to sanction them was an abuse of discretion.

Under Garrett, such an underdeveloped argument does not warrant appellate review. The court explicitly stated that Lucas’s theory was “inadequate to require us to conduct any further analysis.”

3. Standard of Review for Civil Contempt / Sanctions: Acosta v. Paragon Contractors Corp.

The Tenth Circuit reviewed the contempt sanctions for abuse of discretion, citing Acosta v. Paragon Contractors Corp., 884 F.3d 1225, 1238 (10th Cir. 2018). Under that standard:

• The appellate court gives substantial deference to the district judge’s choice of sanction;
• It overturns only if the decision is “arbitrary, capricious, whimsical or manifestly unreasonable,” or rests on a clearly erroneous view of the law or clearly erroneous factual findings.

This high level of deference is especially important where, as here, the sanction is closely tied to the district court’s management of its docket and enforcement of its own orders.

4. Elements of Civil Contempt: United States v. Ford

The panel quoted United States v. Ford, 514 F.3d 1047, 1051 (10th Cir. 2008), for the elements a movant must prove by clear and convincing evidence to obtain a finding of civil contempt:

1. A valid court order existed;
2. The defendant had knowledge of the order; and
3. The defendant disobeyed the order.

Lucas did not dispute any of these elements:

• The June 9, 2023 order was valid and plainly restricted him from filing new related suits against a defined set of parties;
• He knew about the order; and
• He filed the Jackson County, Missouri lawsuit anyway.

With those elements conceded, the focus legitimately shifted to the sanction, not to the existence of contempt.

5. Objective Reasonableness in Civil Contempt: Taggart v. Lorenzen

To address Lucas’s argument that his violation was justified by his understanding of Missouri law, the court cited Taggart v. Lorenzen, 587 U.S. 554 (2019). Taggart holds that:

• A party’s subjective belief that they are complying with a court order generally does not shield them from civil contempt if that belief is objectively unreasonable;
• The proper inquiry is an objective one: whether there is a “fair ground of doubt” as to whether the order barred the conduct in question.

Here, Lucas admitted that:

• He knew of the no‑suit order;
• He intentionally filed a lawsuit against Dadson and related parties concerning the same underlying dispute; and
• He did so because he believed Missouri dissolution law required him to “press” his claims and push for settlement.

The Tenth Circuit effectively concluded that this belief did not create a “fair ground of doubt” as to the meaning or applicability of the June 9, 2023 order. His argument was not that he misunderstood the order but that he thought he had a new substantive legal ground overriding it. Under Taggart, that is not a defense to contempt; the remedy for disagreement with a court order is a motion to modify or vacate, not unilateral disobedience.

6. Appellate Jurisdiction and Unimposed Sanctions: Teaford v. Ford Motor Co.

Lucas argued error in the fact that at the hearing defendants orally requested a 24‑hour confinement and the district court briefly discussed the possibility. The Tenth Circuit rejected this complaint for lack of appellate jurisdiction, citing Teaford v. Ford Motor Co., 338 F.3d 1179 (10th Cir. 2003).

In Teaford, the court held that where the alleged injury does “not rise to the level of a sanction order, [the plaintiff] has nothing from which to appeal.” Applied here:

• No criminal contempt proceedings were initiated;
• No criminal sanction (such as a fixed jail term or punitive fine) was ordered; and
• Thus, there was no adverse order to review.

Mere discussion of a possible future sanction, or an oral request that never ripens into an order, is not an appealable injury.

7. Judicial Bias Standard: Liteky v. United States

Lucas accused the district judge of allowing anger and disrespect to “infuse and color” the proceedings with bias. The Tenth Circuit applied Liteky v. United States, 510 U.S. 540 (1994), which distinguishes between:

• Ordinary judicial expressions of irritation, skepticism, or even sharp criticism of a party’s conduct in the litigation; and
• “Deep‑seated favoritism or antagonism” that would make fair judgment impossible.

As Liteky explains, adverse rulings and case‑related criticism “almost never constitute a valid basis for a bias or partiality motion.”

The Tenth Circuit concluded that the district judge’s displeasure was explicitly grounded in Lucas’s litigation behavior, including his violation of a clear order and his persistent attempts to relitigate settled matters. Nothing in the record suggested an extra‑judicial or personal animus. Hence, no bias requiring recusal or reversal.

B. The Court’s Legal Reasoning

1. No Abuse of Discretion in Refusing to Sanction Defendants

Lucas contended that defendants had an obligation under Mo. Rev. Stat. § 351.478 to notify “known claimants” of Dadson’s dissolution and that their failure to disclose this to him or the court was sanctionable. The district court had rejected this theory, stressing:

• Under Missouri law, dissolution does not abate or suspend pending proceedings, nor does it prevent the corporation from suing or being sued;
• Thus, the dissolution was immaterial to the federal action, which had commenced before the effective date of dissolution; and
• Lucas had not pointed to any order that defendants violated or any duty to disclose dissolution status in federal court.

On appeal, Lucas re‑asserted that Missouri law permits dissolved corporations to engage in only “five types of actions” and that continued litigation exceeded those categories. The Tenth Circuit saw no statutory or case‑law support for that claim. It also emphasized that Lucas failed to:

• Show that the Missouri statutes created a federal duty to disclose dissolution to the district court; or
• Demonstrate why failure to do so constituted sanctionable conduct under Fed. R. Civ. P. 11 or the court’s inherent powers.

Applying the abuse‑of‑discretion standard, and guided by Garrett, the Tenth Circuit concluded the argument was too undeveloped to warrant analysis and that nothing suggested the district court’s refusal to sanction defendants was arbitrary or legally erroneous.

2. Upholding the Civil Contempt Sanction Against Lucas

The court affirmed the contempt sanction on straightforward grounds:

1. Existence, knowledge, and violation of the order: Under Ford, Lucas’s contempt was established once it was shown—and he did not dispute—that:
   • A valid June 9, 2023 no‑suit order existed;
   • He knew of it; and
   • He violated it by filing a new lawsuit in Jackson County, Missouri, against entities covered by the order and concerning the same underlying dispute.
2. No legal justification for disobedience: Lucas argued that defendants’ failure to disclose Dadson’s dissolution induced or justified his Missouri filing. The Tenth Circuit:
   • Held that defendants had no duty to accept his settlement offer or to cease litigation upon dissolution; and
   • Found no support for his interpretation of Missouri law as compelling immediate liquidation in the specific way he claimed.
3. Subjective belief is no defense if unreasonable: Even assuming Lucas genuinely believed Missouri law permitted or required him to proceed, Taggart makes plain that:

   “a party's subjective belief that she was complying with an order ordinarily will not insulate her from civil contempt if that belief was objectively unreasonable.”

   Lucas’s conduct—directly contravening a clear federal order without seeking relief from that order—was, in the court’s view, objectively unreasonable.

4. Scope of fees awarded: Lucas argued the defendants should not receive fees for work performed before the June 9, 2023 order. The district court, however, had explicitly warned that if Lucas violated that order, it would consider sanctions relating to both:
   • Pre‑order misconduct (for which a sanctions motion had been withdrawn as part of the no‑suit deal); and
   • Post‑order misconduct (the violation itself and resulting litigation).

   The Tenth Circuit found no error in awarding fees encompassing both time periods.

5. “Offset” Argument Rejected: Lucas also claimed the sanction should be reduced by the costs defendants would have incurred anyway had he filed the post‑dissolution suit in federal court instead of state court. The panel characterized this as “nonsensical”:
   • Any new related suit—federal or state—would have violated the same no‑suit order; and
   • The defendants’ costs in responding to the forbidden suit are precisely the type of harm civil contempt sanctions are designed to remedy.

Overall, the sanction—roughly $43,000 in fees and costs—was upheld as a reasonable exercise of the district court’s remedial powers in civil contempt.

3. No Appeal from a Criminal Sanction Never Imposed

Lucas objected that defendants sought a criminal-type sanction (24‑hour incarceration) at the hearing and that the district judge entertained the idea. The Tenth Circuit pointed out:

• The district court refused to act on that oral request because it had not been properly noticed in a written motion;
• No criminal contempt proceedings, with requisite due process protections, were initiated; and
• No criminal penalty was ordered.

Under Teaford, without an actual sanction order, there is no appealable injury. The court therefore dismissed this complaint as jurisdictionally defective.

4. Rejecting the Judicial Bias Claim

Lucas’s final argument was that the district judge’s anger and “disrespect” created bias that tainted the hearing and decision‑making. Applying Liteky, the Tenth Circuit emphasized:

• Judicial remarks that are “critical or disapproving of, or even hostile to, counsel, the parties, or their cases” do not ordinarily support a finding of bias;
• Bias must usually arise from an extrajudicial source or manifest as deep‑seated antagonism that makes fair judgment impossible; and
• Here, the judge’s displeasure was directly tied to Lucas’s choice to violate a clear order and to engage in repetitive, vexatious litigation.

In context, such frustration was a natural, case‑related reaction and not evidence of disqualifying bias.

C. Impact and Doctrinal Significance

1. Enforcement of No‑Suit Orders and Vexatious Litigation Controls

A core practical lesson from this case is how federal courts enforce no‑suit agreements and orders entered to curb vexatious or repetitive litigation:

• When a party agrees in open court to a no‑suit condition in exchange for leniency (such as withdrawal of a sanctions motion), that agreement can be—and here was—converted into a binding court order.
• Violating such an order exposes the violator to:
  • Civil contempt findings; and
  • Substantial fee‑shifting to compensate the other side for litigation spawned by the violation.
• The sanction may encompass both past and future misconduct, especially when the court has explicitly reserved that power as part of the original deal.

This decision thus reinforces the efficacy of no‑filing injunctions, consent orders, and settlement‑linked sanctions regimes as tools for trial courts to manage serial litigants and protect defendants and judicial resources from re‑litigation of settled disputes.

2. Corporate Dissolution Does Not Automatically End Litigation

Lucas’s contention that Dadson’s dissolution compelled a settlement or barred continued defense underscores a recurring misunderstanding about corporate dissolution:

• Under many corporate codes, including Missouri’s, dissolution does not immediately end the corporation’s legal existence; it enters a winding‑up phase.
• During winding up, the corporation:
  • May still sue and be sued;
  • May collect assets, discharge liabilities, and distribute remaining property; and
  • May continue litigation that bears on the proper resolution of claims and obligations.
• Nothing in § 351.476 suggests that a dissolved corporation must accept any settlement offer that comes along or is disabled from defending itself in existing litigation.

The Tenth Circuit’s reliance on the statutory text confirms that administrative dissolution is not, by itself, a strategy for claimants to force a defendant into early settlement or to circumvent prior federal orders.

3. Objective Standard for Contempt and the Limits of “Good Faith”

The opinion’s invocation of Taggart reinforces an important conceptual point in contempt law:

• Civil contempt is fundamentally remedial—its goal is to compel obedience and compensate for harm caused by noncompliance.
• The standard is objective: could a reasonable person, aware of the order and the circumstances, believe the prohibited conduct was actually permitted?
• Even sincere, subjective good faith does not excuse disobedience if that belief is legally untenable.

This is especially salient for pro se litigants, who may feel morally justified or legally convinced of the rightness of their position. The decision squarely affirms that:

• Believing an order is wrong or unfair does not license self‑help; and
• The proper avenue is to seek modification or appellate review—not to disregard the order and then justify the violation with legal theories.

4. Pro Se Appellants Must Adequately Brief Issues

Building on Garrett, the decision underscores that while courts give pro se litigants some latitude, they cannot:

• Ignore basic appellate rules requiring:
  • Statement of the issues;
  • Argument section with supporting authority; and
  • Engagement with the standard of review and relevant facts.
• Expect appellate judges to comb the record and construct legal theories on their behalf.

In practical terms, this case signals that unsupported assertions of “misstatement of law” or “bias,” without more, will be swiftly rejected on appeal.

5. Clear Separation of Civil and Criminal Contempt

The distinction between civil and criminal contempt is sometimes blurred in practice. This case illustrates that:

• Civil contempt sanctions (here, compensation for attorney’s fees and costs) are directly tied to the harm caused by the violation and are permissible under the court’s inherent authority and Rule 37/Rule 11‑type powers.
• Criminal contempt requires additional procedural protections and is punitive, aimed at vindicating the court’s authority rather than compensating an adversary.
• An offhand oral request for jail time, rejected as procedurally improper, does not trigger criminal contempt procedures or create an appealable issue.

The Tenth Circuit’s jurisdictional analysis ensures that appellate review of sanctions is limited to actual, entered orders, not hypothetical or suggested penalties.

6. Managing Accusations of Judicial Bias

Finally, the decision’s reliance on Liteky serves as a reminder that:

• Tough language, impatience, or evident frustration from a judge in response to a party’s conduct—even if harsh—is not, by itself, grounds for reversal;
• Bias must arise from an improper source or manifest as an incapacity to fairly adjudicate, not simply from the judge’s adverse reaction to a litigant’s repeated violation of orders; and
• Claims of bias are particularly weak where the judge’s remarks are motivated by the party’s ongoing disregard of prior rulings and agreements—as was the case with Lucas.

V. Simplifying Key Legal Concepts

A. Civil Contempt vs. Criminal Contempt

• Civil Contempt:
  • Purpose: To coerce compliance with a court order or to compensate another party for losses from noncompliance.
  • Sanctions: Often monetary (fees, costs); sometimes conditional incarceration (e.g., “you remain jailed until you comply”).
  • Key Feature: The contemnor “holds the keys” to their own release by choosing to comply.
• Criminal Contempt:
  • Purpose: To punish past disobedience and vindicate the court’s authority.
  • Sanctions: Fixed fines, set jail terms, etc.
  • Procedural Protections: More like a criminal case—notice, possibly jury trial for serious sanctions, proof beyond a reasonable doubt, etc.

In Lucas, the sanctions were purely civil: fee‑shifting to compensate defendants for having to respond to a forbidden suit and attend a contempt hearing. No criminal contempt procedures were initiated.

B. Administrative Dissolution and Winding Up

When a corporation is administratively dissolved (e.g., for failure to file reports or pay fees), it does not immediately vanish. Instead:

• It enters a “winding‑up” phase where it:
  • Settles debts;
  • Collects and sells assets;
  • Distributes remaining property to owners; and
  • May complete or resolve ongoing business, including litigation.
• Statutes like Mo. Rev. Stat. § 351.476 clarify that:
  • Existing lawsuits continue despite dissolution; and
  • New lawsuits may still be brought by or against the corporation in its own name.

Thus, dissolution is not a magic wand enabling claimants to demand settlement on their terms or invalidating past litigation conduct.

C. Abuse of Discretion

An appellate court reviews many trial‑level decisions—especially sanctions—for “abuse of discretion.” This means:

• The decision stands unless:
  • It rests on the wrong legal standard;
  • It reflects a clearly erroneous view of the facts; or
  • It is so unreasonable that no fair‑minded judge could have reached it.

Because the district court in Lucas:

• Applied the correct contempt standard;
• Relied on undisputed facts about the existence and violation of the order; and
• Imposed a sanction tailored to the fees and costs actually incurred,

the Tenth Circuit could not conclude that the court abused its discretion.

D. Appellate Standing and Appealability

To appeal, a party must show:

• Standing—they suffered an actual, concrete injury traceable to the order they challenge; and
• Appealable Order—the order is final or falls within an exception (e.g., certain interlocutory orders).

In the context of sanctions:

• A party may appeal a sanction order that actually imposes a penalty;
• They may not appeal mere discussions, threatened sanctions, or denied requests unless some distinct harm results.

Because Lucas was never sentenced to jail or otherwise penalized criminally, he had no sanction order from which to appeal on that issue.

E. “Bias” vs. Judicial Frustration

Litigants sometimes interpret stern language or repeated adverse rulings as “bias.” Legally, however:

• Bias requiring recusal usually involves:
  • Personal animus or favoritism originating outside the courtroom; or
  • So much hostility that a fair trial is impossible.
• Ordinary frustration with a party’s litigation conduct—even if sharply worded—is not enough.

In Lucas, the judge’s criticism was grounded in Lucas’s decision to violate a court order and his broader litigation history with the same opponents. That is normal judicial reaction, not disqualifying bias.

VI. Conclusion

Lucas v. Dadson Manufacturing Corporation is, on its face, a fact‑specific dispute about one litigant’s persistent efforts to re‑open a settled controversy and his subsequent violation of a no‑suit order. Yet the opinion offers broader guidance on several recurring legal themes:

• Courts may—and will—use civil contempt and fee‑shifting to enforce no‑filing orders negotiated as part of sanctions resolutions.
• Corporate administrative dissolution under Missouri law does not abate pending litigation or obligate a corporation to accept a claimant’s settlement demand.
• A party’s subjective legal theories, however earnestly held, do not justify disobeying a clear court order when those theories are objectively unreasonable.
• Pro se appellants must still adequately brief issues and cannot rely on the court to piece together theories and comb the record for support.
• Appellate courts lack jurisdiction to review unimposed criminal sanctions, and adverse remarks grounded in litigation conduct do not equate to judicial bias.

For practitioners, the case underscores the importance of:

• Drafting clear no‑suit and sanctions orders with explicit warnings about future violations;
• Recognizing that dissolution statutes generally preserve, not terminate, litigation capacity; and
• Advising clients—especially those inclined to self‑representation—that disagreement with a court order must be addressed through proper channels, not unilateral defiance.

Though non‑precedential, Lucas provides a coherent, persuasive application of established doctrines governing civil contempt, corporate dissolution, and appellate review, and will likely be cited as such in future disputes involving vexatious post‑settlement litigation and enforcement of no‑suit injunctions.