2011-09-19_ENFORCEMENT - M1977300

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here, however, because it dealt with a constitutional vagueness challenge to a statute rather than an order. Where a court is faced with a vagueness challenge to a statute, the court applies a balancing test that takes into account two potentially conflicting concerns: "[The statute] must be specific enough to give fair warning of the prohibited conduct, yet must be sufficiently general to address the problem under varied circumstances and during changing times." Parrish v. Lamm, 758 P.2d 1356, 1368 (Colo. 1988). These conflicting concerns do not arise where, as here, the vagueness test is applied to an order upon which contempt proceedings are based; in such cases, the proper standard is the stricter test established in Golden Press. Numerous courts from other jurisdictions, in the same manner as Golden Press, have emphasized that due process considerations require heightened scrutiny where a court or administrative agency imposes fines to coerce compliance with an order. See Project B.A.S.I. C. v. K e m p , 947 F.2d 1 1 , 17 (1st Cir. 1991) ( "The unflagging need f o r clarity ... derives from concepts of fairness and due process ... because an order commanding a person to act or refrain from acting is inherently coercive.... "). "The judicial contempt power is a potent weapon. When it is founded upon a decree too vague to be understood, it can be a deadly one." International Longshoremen's Ass 'n v. Philadelphia Marine Trade Ass 'n, 389 U.S. 64, 76 (1967). "A contempt order is insufficient if its interpretation requires inferences or conclusions about which reasonable persons might differ." In re Sam Houston, 92 S.W. 3d 870, 877 (Tex. Ct. App. 2002). "To be enforceable by contempt, a decree `must set forth the terms of compliance in clear, specific and unambiguous terms so that the person charged with obeying the decree will readily know exactly what duties and obligations are imposed upon him.'" Id. 13