United States v. United Mine Workers of America
United States v. United Mine Workers of America, 1947 U.S. LEXIS 2954 (1947)
Winning Party
N/A
Key Issue
Declaratory Judgment and Injunctive Relief
Case Type
CIVIL
Summary
In a case involving the United States and the United Mine Workers of America, the Supreme Court affirmed in part and reversed in part the lower court's rulings regarding criminal contempt. The Court held that the District Court had the authority to issue a restraining order and that the Norris-LaGuardia Act did not apply when the government operated the mines. While the fine against union president John L. Lewis was upheld, the Court found the fine against the union excessive, modifying it to $700,000 with additional conditions for compliance.
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Facts
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The defendants were aware that a criminal contempt was charged.
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The contempt had continued for 15 days from the issuance of the restraining order until the finding of guilty.
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The United States filed a petition for a rule to show cause why the defendants should not be punished for contempt for violating the restraining order.
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The defendants were found guilty of criminal contempt.
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A gradual walkout by the miners commenced, leading to a full-blown strike.
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Pending a determination of defendants' right to take this action, the Government requested a temporary restraining order and injunctive relief.
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Terms of employment were governed by an agreement between Secretary of Interior Krug and John L. Lewis, president of the United Mine Workers of America, which incorporated terms from a prior agreement.
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Lewis sought to terminate the Krug-Lewis agreement, asserting a right to negotiate new terms, but the government denied any contractual basis for termination.
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The Government's complaint sought a declaratory judgment in respect to the right of the defendants to terminate the contract by unilateral action.
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What amounted to a strike call, effective at midnight on November 20, had been issued by the defendant Lewis as an "official notice."
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The petition alleged a willful violation of the restraining order.
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The petition and the rule to show cause inquired as to why the defendants should not be "punished as and for a contempt" of court.
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The United States filed a complaint seeking a declaratory judgment that the defendants could not unilaterally terminate the Krug-Lewis agreement and requested a temporary restraining order and preliminary injunction.
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The memorandum in support of the restraining order seriously urged the inapplicability of the Norris-LaGuardia Act to the facts of this case, and the power of the District Court to grant the ancillary relief depended in great part upon the resolution of this jurisdictional question.
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The defendants enjoyed during the trial itself all the enhanced protections accorded defendants in criminal contempt proceedings.
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In October 1946, the United States government possessed and operated the majority of the country's bituminous coal mines.
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The United States government possessed and operated the majority of the country's bituminous coal mines.
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Defendant Lewis stated openly in court that defendants would adhere to their policy of defiance.
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The court issued a temporary restraining order without notice to the defendants, preventing them from encouraging a strike.
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This policy was the germ center of an economic paralysis which was rapidly extending itself from the bituminous coal mines into practically every other major industry of the United States.
Key Holdings
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The District Court had the power to punish violations of its orders as criminal contempt because the court had the power to issue a restraining order for the purpose of preserving existing conditions pending a decision upon its own jurisdiction.
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The Norris-LaGuardia Act did not prevent the District Court from issuing a temporary restraining order and preliminary injunction against the United Mine Workers of America and John L. Lewis because the Act does not apply to the government when it seizes and operates coal mines and the relationship between the government and the workers is that of employer and employee.
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An order issued by a court with jurisdiction over the subject matter and person must be obeyed by the parties until it is reversed by orderly and proper proceedings.
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The record warrants a fine of $10,000 against defendant Lewis for criminal contempt, but the unconditional imposition of a fine of $3,500,000 against the defendant union is excessive.
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The proceedings in the District Court were proper to support judgments for both criminal and civil contempt because the defendants were fairly and completely apprised of the events and conduct constituting the contempt charged, and they enjoyed during the trial itself all the enhanced protections accorded defendants in criminal contempt proceedings.
Citations
United States v. United Mine Workers of America, 1947 U.S. LEXIS 2954, 19 L.R.R.M. (BNA) 2346, 91 L. Ed. 884, 330 U.S. 258, 67 S. Ct. 677 (1947)
Legal Reasoning
The Supreme Court reasoned that the Norris-LaGuardia Act did not apply because the government had seized the mines and was operating them, thus establishing an employer-employee relationship with the miners. The Court also held that the District Court had the power to issue a restraining order to preserve existing conditions while determining its own jurisdiction. The Court further reasoned that the defendants were aware that a criminal contempt was charged and enjoyed all the enhanced protections accorded defendants in criminal contempt proceedings. Finally, the Court reasoned that the fine imposed on the defendant Lewis was warranted, but the fine imposed on the defendant union was excessive and should be modified.
Outcome
The Supreme Court affirmed the temporary restraining order and preliminary injunction. The judgment against the defendant Lewis was affirmed. The judgment against the defendant union was modified to require the union to pay a fine of $700,000, and further, to pay an additional fine of $2,800,000 unless the union, within five days after the issuance of the mandate, shows that it has fully complied with the temporary restraining order and the preliminary injunction.
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