United Mine Workers of America v. Gibbs
Encyclopedia
United Mine Workers of America v. Gibbs, 383 U.S. 715
(1966), was a case in which the Supreme Court of the United States
held that in order for a United States district court
to have pendent jurisdiction
over a state-law cause of action
, state and federal claims must arise from the same "common nucleus of operative fact" and the plaintiff must expect to try them all at once. This case was decided before the existence of the current supplemental jurisdiction
statute, .
in Marion County, Tennessee
. Plaintiff Paul Gibbs was a truck driver
and coal miner who had been hired by the Grundy Company, a wholly owned subsidiary of the Tennessee Consolidated Coal Company, to be the superintendent of a coal mine to be opened near Gray's Creek, and to arrange for the coal to be hauled to the nearest railroad depot. The mine would have been within the jurisdiction United Mine Workers of America (UMW) Local 5881, whose members had previously worked for Tennessee Consolidated. Gibbs had planned instead to use members of the rival Southern Labor Union to work the mine.
News of the mine's planned opening reached the UMW members, and on August 15 and 16, 1960, a group of armed miners from Local 5881 arrived at the site to prevent the mine from being opened. They threatened Gibbs, and beat the Southern Labor Union representative. UMW field representative George Gilbert was away on business in Middlesboro, Kentucky at the time of the incident, and learned of the violence while he was away. Gilbert returned to the site, and established a picket line, which lasted for nine months. There was no further violence at the site, and no further attempts were made by any party to open the mine.
Gibbs lost his job as mine superintendent, and was therefore unable to commence performance of his haulage contract. He also lost some of his other mine lease
s and trucking contract
s elsewhere in the state. Believing that his losses were part of a union conspiracy against him, he sued the United Mine Workers (but not the specific local or its members) in the United States District Court for the Eastern District of Tennessee
. The counts on Gibbs' complaint included allegations that the UMW engaged in a secondary boycott in violation of § 303 of the Labor-Management Relations Act, and that the UMW engaged in tortious interference
with his employment relationship and a civil conspiracy
in violation of the common law
of the state of Tennessee
.
The district court judge refused to submit to the jury
the claims of pressure intended to cause mining firms other than Grundy to cease doing business with Gibbs, finding these claims unsupported by the evidence. The jury's verdict
was that the UMW had violated both § 303 and state law. Gibbs was awarded $60,000 as damages
under the employment contract and $14,500 under the haulage contract; he was also awarded $100,000 punitive damages
. On motion
, the trial court set aside the award of damages with respect to the haulage contract on the ground that the damages were unproved. It also held that union pressure on Grundy to discharge Gibbs as supervisor would constitute only a primary dispute with Grundy, as Gibbs' employer, and hence was not cognizable as a claim under 303. Interference with the employment relationship was cognizable as a state law claim, however, and a remitted award was sustained on that claim. The United States Court of Appeals for the Sixth Circuit
affirmed the district court's decision.
first held that Gibbs' state law claims were not preempted
by federal law, and then moved on to the central issue in the case: whether the district court acted properly in exercising jurisdiction over both the state law and federal law claims. He wrote that the Federal Rules of Civil Procedure
encouraged the joinder
of claims, parties
, and remedies
to the broadest extent possible, in keeping with the principles of judicial economy
and fairness to the parties. However, he noted that pendent jurisdiction
, while it can exist whenever there is a federal question
under Article III, § 2 of the Constitution
, is a matter of discretion for the district court, not a matter of right for the plaintiff. Here, Brennan established the test for pendent jurisdiction known as the "common nucleus of operative fact": the claims must derive from the same situation, such that a plaintiff would ordinarily expect to try them all in one judicial proceeding.
Brennan listed some situations where pendent jurisdiction
would be inappropriate. If the plaintiff's federal law claims are dismissed before trial, the state law claims should be as well; likewise, if the state law claims predominate in the plaintiff's complaint
, the district court may dismiss
the state law claims without prejudice for a state court to hear. Also, Brennan explained that in some cases, the likelihood of jury confusion in dealing with separate legal theories of relief could militate in favor of separate trials for the state and federal claims. Brennan concluded that even though the jury ruled against plaintiff on his federal claim, the preemption issue created a particularly good reason for exercising pendent jurisdiction in this case.
Brennan also held that the district court improperly instructed the jury on the conspiracy count, because the damages plaintiff was claiming must be proximately caused
by violence or threats thereof, and that plaintiff had not shown "clear proof" that the UMW's management had endorsed violence as a means of settling the dispute (as required under the Norris-LaGuardia Act
).
wrote a brief concurrence, in which he agreed with Brennan's discussion of pendent jurisdiction, but disagreed with his interpretation of the standard of proof required for a claim under the Norris-LaGuardia Act.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1966), was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that in order for a United States district court
United States district court
The United States district courts are the general trial courts of the United States federal court system. Both civil and criminal cases are filed in the district court, which is a court of law, equity, and admiralty. There is a United States bankruptcy court associated with each United States...
to have pendent jurisdiction
Pendent jurisdiction
Pendent jurisdiction is the authority of a United States federal court to hear a closely related state law claim against a party already facing a federal claim, described by the Supreme Court as "jurisdiction over nonfederal claims between parties litigating other matters properly before the...
over a state-law cause of action
Cause of action
In the law, a cause of action is a set of facts sufficient to justify a right to sue to obtain money, property, or the enforcement of a right against another party. The term also refers to the legal theory upon which a plaintiff brings suit...
, state and federal claims must arise from the same "common nucleus of operative fact" and the plaintiff must expect to try them all at once. This case was decided before the existence of the current supplemental jurisdiction
Supplemental jurisdiction
Supplemental jurisdiction is the authority of United States federal courts to hear additional claims substantially related to the original claim even though the court would lack the subject-matter jurisdiction to hear the additional claims independently. is a codification of the Supreme Court's...
statute, .
Facts and procedural history
This case arose out of a dispute between two labor unions over the representation of coal minersCoal mining
The goal of coal mining is to obtain coal from the ground. Coal is valued for its energy content, and since the 1880s has been widely used to generate electricity. Steel and cement industries use coal as a fuel for extraction of iron from iron ore and for cement production. In the United States,...
in Marion County, Tennessee
Marion County, Tennessee
Marion County is a county located in the U.S. state of Tennessee. As of 2000, the population was 27,776. Its county seat is Jasper.Marion County is part of the Chattanooga, TN–GA Metropolitan Statistical Area.-Geography:According to the U.S...
. Plaintiff Paul Gibbs was a truck driver
Truck driver
A truck driver , is a person who earns a living as the driver of a truck, usually a semi truck, box truck, or dump truck.Truck drivers provide an essential service to...
and coal miner who had been hired by the Grundy Company, a wholly owned subsidiary of the Tennessee Consolidated Coal Company, to be the superintendent of a coal mine to be opened near Gray's Creek, and to arrange for the coal to be hauled to the nearest railroad depot. The mine would have been within the jurisdiction United Mine Workers of America (UMW) Local 5881, whose members had previously worked for Tennessee Consolidated. Gibbs had planned instead to use members of the rival Southern Labor Union to work the mine.
News of the mine's planned opening reached the UMW members, and on August 15 and 16, 1960, a group of armed miners from Local 5881 arrived at the site to prevent the mine from being opened. They threatened Gibbs, and beat the Southern Labor Union representative. UMW field representative George Gilbert was away on business in Middlesboro, Kentucky at the time of the incident, and learned of the violence while he was away. Gilbert returned to the site, and established a picket line, which lasted for nine months. There was no further violence at the site, and no further attempts were made by any party to open the mine.
Gibbs lost his job as mine superintendent, and was therefore unable to commence performance of his haulage contract. He also lost some of his other mine lease
Lease
A lease is a contractual arrangement calling for the lessee to pay the lessor for use of an asset. A rental agreement is a lease in which the asset is tangible property...
s and trucking contract
Contract
A contract is an agreement entered into by two parties or more with the intention of creating a legal obligation, which may have elements in writing. Contracts can be made orally. The remedy for breach of contract can be "damages" or compensation of money. In equity, the remedy can be specific...
s elsewhere in the state. Believing that his losses were part of a union conspiracy against him, he sued the United Mine Workers (but not the specific local or its members) in the United States District Court for the Eastern District of Tennessee
United States District Court for the Eastern District of Tennessee
The United States District Court for the Eastern District of Tennessee is the federal court in the Sixth Circuit whose jurisdiction covers all of East Tennessee and a portion of Middle Tennessee. The court has jurisdiction over 41 counties with 4 divisions...
. The counts on Gibbs' complaint included allegations that the UMW engaged in a secondary boycott in violation of § 303 of the Labor-Management Relations Act, and that the UMW engaged in tortious interference
Tortious interference
Tortious interference, also known as intentional interference with contractual relations, in the common law of tort, occurs when a person intentionally damages the plaintiff's contractual or other business relationships...
with his employment relationship and a civil conspiracy
Conspiracy (civil)
A civil conspiracy or collusion is an agreement between two or more parties to deprive a third party of legal rights or deceive a third party to obtain an illegal objective....
in violation of the common law
Common law
Common law is law developed by judges through decisions of courts and similar tribunals rather than through legislative statutes or executive branch action...
of the state of Tennessee
Tennessee
Tennessee is a U.S. state located in the Southeastern United States. It has a population of 6,346,105, making it the nation's 17th-largest state by population, and covers , making it the 36th-largest by total land area...
.
The district court judge refused to submit to the jury
Jury
A jury is a sworn body of people convened to render an impartial verdict officially submitted to them by a court, or to set a penalty or judgment. Modern juries tend to be found in courts to ascertain the guilt, or lack thereof, in a crime. In Anglophone jurisdictions, the verdict may be guilty,...
the claims of pressure intended to cause mining firms other than Grundy to cease doing business with Gibbs, finding these claims unsupported by the evidence. The jury's verdict
Verdict
In law, a verdict is the formal finding of fact made by a jury on matters or questions submitted to the jury by a judge. The term, from the Latin veredictum, literally means "to say the truth" and is derived from Middle English verdit, from Anglo-Norman: a compound of ver and dit In law, a verdict...
was that the UMW had violated both § 303 and state law. Gibbs was awarded $60,000 as damages
Damages
In law, damages is an award, typically of money, to be paid to a person as compensation for loss or injury; grammatically, it is a singular noun, not plural.- Compensatory damages :...
under the employment contract and $14,500 under the haulage contract; he was also awarded $100,000 punitive damages
Punitive damages
Punitive damages or exemplary damages are damages intended to reform or deter the defendant and others from engaging in conduct similar to that which formed the basis of the lawsuit...
. On motion
Motion (legal)
In law, a motion is a procedural device to bring a limited, contested issue before a court for decision. A motion may be thought of as a request to the judge to make a decision about the case. Motions may be made at any point in administrative, criminal or civil proceedings, although that right is...
, the trial court set aside the award of damages with respect to the haulage contract on the ground that the damages were unproved. It also held that union pressure on Grundy to discharge Gibbs as supervisor would constitute only a primary dispute with Grundy, as Gibbs' employer, and hence was not cognizable as a claim under 303. Interference with the employment relationship was cognizable as a state law claim, however, and a remitted award was sustained on that claim. The United States Court of Appeals for the Sixth Circuit
United States Court of Appeals for the Sixth Circuit
The United States Court of Appeals for the Sixth Circuit is a federal court with appellate jurisdiction over the district courts in the following districts:* Eastern District of Kentucky* Western District of Kentucky...
affirmed the district court's decision.
Majority opinion
Justice BrennanWilliam J. Brennan, Jr.
William Joseph Brennan, Jr. was an American jurist who served as an Associate Justice of the United States Supreme Court from 1956 to 1990...
first held that Gibbs' state law claims were not preempted
Federal preemption
Federal preemption refers to the invalidation of US state law when it conflicts with Federal law.-Constitutional basis:According to the Supremacy Clause of the United States Constitution,...
by federal law, and then moved on to the central issue in the case: whether the district court acted properly in exercising jurisdiction over both the state law and federal law claims. He wrote that the Federal Rules of Civil Procedure
Federal Rules of Civil Procedure
The Federal Rules of Civil Procedure govern civil procedure in United States district courts. The FRCP are promulgated by the United States Supreme Court pursuant to the Rules Enabling Act, and then the United States Congress has 7 months to veto the rules promulgated or they become part of the...
encouraged the joinder
Joinder
Joinder is a legal term, which refers to the process of joining two or more legal issues together to be heard in one hearing or trial. It is done when the issues or parties involved overlap sufficiently to make the process more efficient or more fair...
of claims, parties
Party (law)
A party is a person or group of persons that compose a single entity which can be identified as one for the purposes of the law. Parties include: plaintiff , defendant , petitioner , respondent , cross-complainant A party is a person or group of persons that compose a single entity which can be...
, and remedies
Legal remedy
A legal remedy is the means with which a court of law, usually in the exercise of civil law jurisdiction, enforces a right, imposes a penalty, or makes some other court order to impose its will....
to the broadest extent possible, in keeping with the principles of judicial economy
Judicial economy
Judicial economy refers broadly to the principle that the limited resources of the legal system or a given court should be conserved.-Multiple causes of action in a given case :...
and fairness to the parties. However, he noted that pendent jurisdiction
Pendent jurisdiction
Pendent jurisdiction is the authority of a United States federal court to hear a closely related state law claim against a party already facing a federal claim, described by the Supreme Court as "jurisdiction over nonfederal claims between parties litigating other matters properly before the...
, while it can exist whenever there is a federal question
Federal question jurisdiction
Federal question jurisdiction is a term used in the United States law of civil procedure to refer to the situation in which a United States federal court has subject-matter jurisdiction to hear a civil case because the plaintiff has alleged a violation of the Constitution or law of the...
under Article III, § 2 of the Constitution
Article Three of the United States Constitution
Article Three of the United States Constitution establishes the judicial branch of the federal government. The judicial branch comprises the Supreme Court of the United States and lower courts as created by Congress.-Section 1: Federal courts:...
, is a matter of discretion for the district court, not a matter of right for the plaintiff. Here, Brennan established the test for pendent jurisdiction known as the "common nucleus of operative fact": the claims must derive from the same situation, such that a plaintiff would ordinarily expect to try them all in one judicial proceeding.
Brennan listed some situations where pendent jurisdiction
Pendent jurisdiction
Pendent jurisdiction is the authority of a United States federal court to hear a closely related state law claim against a party already facing a federal claim, described by the Supreme Court as "jurisdiction over nonfederal claims between parties litigating other matters properly before the...
would be inappropriate. If the plaintiff's federal law claims are dismissed before trial, the state law claims should be as well; likewise, if the state law claims predominate in the plaintiff's complaint
Complaint
In legal terminology, a complaint is a formal legal document that sets out the facts and legal reasons that the filing party or parties In legal terminology, a complaint is a formal legal document that sets out the facts and legal reasons (see: cause of action) that the filing party or parties In...
, the district court may dismiss
Involuntary dismissal
Involuntary dismissal is the termination of a court case despite the plaintiff's objection.In United States Federal courts, involuntary dismissal is governed by Federal Rules of Civil Procedure Rule 41....
the state law claims without prejudice for a state court to hear. Also, Brennan explained that in some cases, the likelihood of jury confusion in dealing with separate legal theories of relief could militate in favor of separate trials for the state and federal claims. Brennan concluded that even though the jury ruled against plaintiff on his federal claim, the preemption issue created a particularly good reason for exercising pendent jurisdiction in this case.
Brennan also held that the district court improperly instructed the jury on the conspiracy count, because the damages plaintiff was claiming must be proximately caused
Proximate cause
In the law, a proximate cause is an event sufficiently related to a legally recognizable injury to be held the cause of that injury. There are two types of causation in the law, cause-in-fact and proximate cause. Cause-in-fact is determined by the "but-for" test: but for the action, the result...
by violence or threats thereof, and that plaintiff had not shown "clear proof" that the UMW's management had endorsed violence as a means of settling the dispute (as required under the Norris-LaGuardia Act
Norris-LaGuardia Act
The Norris–La Guardia Act was a 1932 United States federal law that banned yellow-dog contracts, barred federal courts from issuing injunctions against nonviolent labor disputes, and created a positive right of noninterference by employers against workers joining trade unions...
).
Concurring opinion
Justice HarlanJohn Marshall Harlan II
John Marshall Harlan was an American jurist who served as an Associate Justice of the Supreme Court from 1955 to 1971. His namesake was his grandfather John Marshall Harlan, another associate justice who served from 1877 to 1911.Harlan was a student at Upper Canada College and Appleby College and...
wrote a brief concurrence, in which he agreed with Brennan's discussion of pendent jurisdiction, but disagreed with his interpretation of the standard of proof required for a claim under the Norris-LaGuardia Act.