United Mine Workers of America v. Gibbs

Facts

The case grew out of a rivalry between the United Mine Workers of America (the UMW) and the Southern Labor Union over representing workers in the southern Appalachian coal fields. In the spring of 1960, Tennessee Consolidated Coal Company closed a mine in southern Tennessee and laid off 100 miners who belonged to the UMW's Local 5881. Late that summer, Grundy Company, a wholly owned subsidiary of Consolidated, hired Paul Gibbs as mine superintendent to try to open a new mine at nearby Gray's Creek with members of the Southern Labor Union. Grundy also gave Gibbs a contract to haul the mine's coal to the nearest railroad loading point. On August 15 and 16, 1960, armed members of Local 5881 forcibly kept the mine from opening. They threatened Gibbs and beat an organizer for the rival union. They believed Consolidated had promised them the jobs at the new mine. No representative of the international union was there. George Gilbert, the UMW's field representative, was away at a meeting in Kentucky. He returned late on August 16 with instructions to set up a limited picket line, prevent further violence and keep the strike from spreading. There was no further violence at the mine site. Gibbs lost his job as superintendent and never performed the haulage contract. He testified that he soon began to lose other trucking contracts and mine leases.

Issues

1. Did the District Court have power to decide Gibbs's Tennessee claim together with his § 303 claims when there was no diversity jurisdiction, and did it exceed its discretion by deciding that claim?
2. Under the pre-emption doctrine, may a state tort claim arising from a labor dispute recover for the consequences of associated peaceful picketing, or only for the direct consequences of violence?
3. Does § 6 of the Norris-LaGuardia Act, which requires clear proof before a union is held liable for the unlawful acts of its officers, members or agents, govern federal-court adjudication of state tort claims arising out of labor disputes, and was that proof offered here?

Holding

The District Court had power to decide Gibbs's state claim, because the § 303 claims were substantial and the state and federal claims arose from the same nucleus of operative fact, and it did not exceed its discretion in keeping the claim. The judgment was still reversed: § 6 of the Norris-LaGuardia Act governs federal-court adjudication of state tort claims arising out of labor disputes, and the record held no clear proof that the UMW participated in, authorized or ratified the violence.