Civil Procedure Keyed to Subrin
United Mine Workers of America v. Gibbs
ProfessorBrittany L. Raposa
CaseCast™ – "What you need to know"
Facts
Tennessee Consolidated Coal Company hired Gibbs, Plaintiff, to be a mine superintendent and to haul coal from one of the company’s mines. When Plaintiff went to the mine, members of United Mine Workers of America (a rival union of the current mine workers’ union) blocked the mine and beat up Plaintiff. Plaintiff was then fired and never started the haulage contract. Plaintiff also lost other mining and trucking contracts after the incident. Plaintiff sued the union, alleging that the loss of his jobs was part of a union conspiracy, which was unlawful under Section 303 of the Labor Management Relations Act of 1947. Plaintiff also asserted a state law claim, which was granted jurisdiction based on the doctrine of pendent jurisdiction. The jury returned a verdict for Plaintiff. Damages recovered were the amount of the employment contract and the haulage contract, plus punitive damages. The trial court set aside the damages relating to the haulage contract (because damages were n ot proved) and the employment contract (finding this contract was between Tennessee Coal and Plaintiff, not Defendant, and therefore did not violate Section 303). The trial court did find a claim under state law, and remitted the award on a state law claim. Defendant appealed. Court of Appeals affirmed. The Supreme Court granted certiorari.
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