Escalating Enforcement When Defendants Refuse to Comply with Court Orders

Court orders are not suggestions. Yet in business litigation, it is not uncommon for defendants to test the limits of compliance — particularly after a judgment or injunction has already been entered against them.

In D’Angelo, on behalf of Esme Designs, LLC v. Kwoka et al., enforcement efforts did not end with the issuance of clear judicial directives. Instead, continued resistance required a measured but persistent escalation of remedies, illustrating how enforcement often unfolds in real-world commercial disputes.