Saturday, December 28, 2013

United States v. United Mine Workers case brief

United States v. United Mine Workers case brief summary
330 U.S. 258 (1947)

CASE SYNOPSIS
Defendants, a union and its leader, sought review of the issuance of injunctions and judgments of contempt against defendants and in favor of plaintiff United States with regard to its seizure of a coal mine. The Supreme Court granted certiorari while an appeal to the United States Court of Appeals for the District of Columbia was pending.

CASE FACTS
The Supreme Court affirmed the issuance of a temporary restraining order, a preliminary injunction, and contempt judgments, but modified the judgment against defendant union with regard to sanctions for contempt. The district court had jurisdiction to issue the injunction and the restraining order. The Norris-LaGuardia Act, which stripped federal courts of power to issue injunctions in cases involving labor disputes, did not apply to the government acting as sovereign in seizing and operating coal mines.

DISCUSSION

  • The Court held that the relationship between the government and the workers of the seized mines was that of governmental employer and employee. 
  • The district court also had the power to punish violation of its orders as criminal and civil contempt because it had the power to preserve existing conditions while it determined its own authority to grant injunctive relief. 
  • Defendants' wilful failure to comply with the order was punishable as criminal contempt.
CONCLUSION
The Supreme Court affirmed the issuance of a temporary restraining order and a preliminary injunction against defendant union. The district court was not prohibited from issuing orders in the labor dispute because the government was acting as sovereign. Sanctions for contempt were proper because defendants were obliged to follow orders while the Court determined jurisdiction. The sanction against defendant union, however, was excessive.


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