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United Mine Workers of America v. Gibbs

(1966)

Supreme Court of the United States - 383 U.S. 715

tl;dr:

For pendent jurisdiction to be asserted, the federal and state claims must derive from the same nucleus of operative fact.

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Case Summary

In the 1966 case United Mine Workers of America v. Gibbs, the U.S. Supreme Court ruled on pendent jurisdiction and federalism. The case involved a conflict between a coal company and a union regarding worker representation in a Tennessee mine. Gibbs, a nonunion member, was hired as mine superintendent and given a contract to haul coal. Union members from a United Mine Workers of America affiliate attempted to stop Gibbs from operating the mine and assaulted him. Gibbs sued the union in federal court for violating federal labor law and for interfering with his contracts under Tennessee law.

While the jury initially ruled in Gibbs's favor for both claims, the trial court later dismissed the federal claim due to lack of evidence, leaving the state claim in a jurisdictional limbo. The Supreme Court ultimately ruled that a federal court can still have pendent jurisdiction over a state claim, even if the federal claim has been dismissed, depending on the circumstances of the case.

This ruling was significant because it established principles of pendent jurisdiction and federalism, and made distinctions between different types of claims based on their source and connection. It also demonstrated how the court would balance efficiency and justice against comity and respect when assessing the scope of federal judicial power. The case still serves as an authority on this topic today.

ICRAIssue, Conclusion, Rule, Analysis for United Mine Workers of America v. Gibbs

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Facts & HoldingUnited Mine Workers of America v. Gibbs case brief facts & holding

Facts:Gibbs was hired by Grundy Company (subsidiary of TN Consolidated...

Holding:The federal government is permitted to assert pendent jurisdiction in...

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United Mine Workers of America v. Gibbs | Case Brief DeepDive
Majority opinion, author: Mr. Justice Brennan
Level 1
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The case involves Paul Gibbs suing the United Mine Workers of America (UMW) for violating § 303 of the Labor Management Relations Act, 1947 and the common law of Tennessee. The dispute arose over representation of workers in the southern Appalachian coal fields. Gibbs alleged secondary boycotts under § 303 and interference with his employment and haulage contracts. The trial judge refused to submit to the jury the claims of pressure on mining firms other than Grundy to cease doing business with Gibbs. The jury found the UMW violated both § 303 and state law and awarded damages to Gibbs. The trial court set aside the award of damages with respect to the haulage contract and held that union pressure on Grundy was not cognizable as a claim under § 303. The Court of Appeals affirmed, but the Supreme Court reversed, questioning whether the District Court had jurisdiction over the claim based on Tennessee law. The state claim is based on violence and intimidation, which falls under the traditional law of torts. The Hum test clarified that a plaintiff can only recover once for a single wrongful invasion of a single primary right, regardless of the number or variety of facts alleged. Pendent jurisdiction is a discretionary doctrine that allows the entire action to be considered one constitutional "case" when a claim arises under federal law and the relationship between that claim and the state claim allows it. State remedies in labor disputes are limited to compensating for the direct consequences of violent conduct, as defined by the traditional law of torts. Recovery can only be had for damages resulting from violent conduct. The petitioner's claim of "conspiracy" to interfere with contractual relations is poorly defined and may have been used as a weapon against the labor movement. Under state law, it would not matter if the union did not authorize, participate in, or ratify the violence. It would only be necessary to show the union's involvement in the conspiracy and that the violent acts were related to the conspiracy's purpose.

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Opinion (Concurrence), author: Mr. Justice Harlan
Level 1
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Justice Harlan agrees with the Court's opinion on pendent jurisdiction but disagrees with the Court's interpretation of the Norris-LaGuardia Act, which he believes is narrower. He notes that the lower court's decision was incorrect. The speaker disagrees with the Court's interpretation of the statutory requirement for union liability, arguing that it introduces inconsistency and reduces the quantum-of-proof requirements in criminal cases. The speaker believes that the statute is directed against a particular type of inferential proof of authority or ratification. The lower court's decision may have been based on an incorrect interpretation of the statute. The speaker agrees with the reversal of the lower court's decision, as there is little evidence connecting the violence to the union, except for a few ambiguous incidents.

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