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Paula Corbin Jones United States of America, Office of the Independent Counsel, Intervenor Below v. William Jefferson Clinton Danny Ferguson Dolly Kyle Browning, Movant-Appellant

Citations: 206 F.3d 811; 2000 U.S. App. LEXIS 4444Docket: 99-2216

Court: Court of Appeals for the Eighth Circuit; March 21, 2000; Federal Appellate Court

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Dolly Kyle Browning, a nonparty witness in Paula Corbin Jones's civil lawsuit against President William Jefferson Clinton, filed a motion in the district court seeking to hold Clinton in criminal contempt, recuse the court, and transfer the case to Texas. The district court denied her motion and subsequently found Clinton in civil contempt for violating discovery orders and providing false deposition testimony. 

Browning appealed the district court's civil contempt order and the denial of her motion. However, the Eighth Circuit Court of Appeals ruled that Browning lacked standing to bring the appeal, as she was not a named party in the underlying case and did not intervene. The court cited precedent indicating that only named parties or those who have achieved party status may initiate an appeal. Furthermore, Browning did not have a sufficient interest in the litigation to be privy to the record necessary for an appeal. The court also noted that as a private individual, Browning had no standing to pursue a criminal contempt claim or appeal the district court's decision regarding that issue. Consequently, the court dismissed her appeal.