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Civil Procedure Keyed to Babcock
United Mine Workers of America v. Gibbs
Citation:
383 U.S. 715, 86 S. Ct. 1130, 16 L. Ed. 2D 218 (1966)
ProfessorBrittany L. Raposa
CaseCast™ – "What you need to know"
Facts
In 1960, Tennessee Consolidated Coal Company closed one of its mines, laying off 100 UMW miners. Later that summer, Grundy Company (a subsidiary of Consolidated) hired Paul Gibbs as superintendent to open a new mine using members of the Southern Labor Union, a rival to UMW. Grundy also gave Gibbs a contract to haul coal from the mine. On August 15-16, 1960, armed members of UMW Local 5881 forcibly prevented the mine’s opening, threatening Gibbs and beating an organizer for the rival union. The UMW field representative, George Gilbert, was away at a meeting during this violence but returned with instructions from his superiors to establish a limited picket line, prevent further violence, and contain the strike. No further violence occurred at the mine site, though picketing continued for nine months. Gibbs lost his superintendent job, never performed his haulage contract, and claimed to lose other business opportunities in the area. He sued the international UMW (not the local union or its members) in federal court, alleging violations of §303 of the Labor Management Relations Act (secondary boycotts) and state tort law for conspiracy and interference with his contracts.
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