Monday, February 11, 2013

United Mine Workers of America v. Gibbs case brief

United Mine Workers of America v. Gibbs case brief summary
383 U.S. 715

PROCEDURAL POSTURE: Petitioner union sought review of a decision of the United States Court of Appeals for the Sixth Circuit, which held in favor of respondent employee on his unfair labor practice action that was brought pursuant to 29 U.S.C.S. § 8 (b)(4).


-The employee was awarded compensatory and punitive damages in an action against petitioner union for alleged violations of federal law governing unfair labor practices. 
-The employee brought his action in federal court in connection with a state court action for unlawful conspiracy and unlawful boycott. 
-The suit stemmed from the conduct of union members, who, through violent means, forcibly prevented the opening of a mine operation supervised by the employee. 

The Court held that even assuming pendent jurisdiction was proper in the case, reversal was required due to the employee's failure to meet special proof requirements imposed by federal law, which required proof that the union ratified the acts of its members.

-While the union members acted in a way that was reprehensible, there was no proof that the union approved of the violent methods. 

-The mere fact of continued picketing at the mine site was not properly relied upon to show ratification. 
-Actual proof existed that the union put a stop to it as soon as it became aware.
-Therefore, the ruling of the appellate court was reversed.


 Pendent jurisdiction, in the sense of judicial power, exists whenever there is a claim arising under the Constitution, the Laws of the United States, and Treaties made, or which shall be made, under their Authority, U.S. Const. art. III, § 2, and the relationship between that claim and the state claim permits the conclusion that the entire action before the court comprises but one constitutional "case." 
-The federal claim must have substance sufficient to confer subject matter jurisdiction on the court. -The state and federal claims must derive from a common nucleus of operative fact. But if, considered without regard to their federal or state character, a plaintiff's claims are such that he would ordinarily be expected to try them all in one judicial proceeding, then, assuming substantiality of the federal issues, there is power in federal courts to hear the whole. 

OUTCOME: Petitioner union was granted relief and the Court reversed the appellate court's ruling in favor of respondent employee, holding that respondent employee could not recover against petitioner union for the actions of its members absent specific proof that the union ratified those actions.

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