United Mine Workers of Am. v. Gibbs

In United Mine Workers of Am. v. Gibbs (1966), 383 U.S. 715, the United Mine Workers ("UMW") and the Southern Labor Union ("SLU") were in the midst of a rivalry over representation of coal workers. During this time, a coal mine shutdown put 100 Local 5881 miners out of work. During the same year, a subsidiary of the company that closed the mine hired Gibbs as a mine superintendent to attempt to open a new mine on nearby property with help from the SLU. Gibbs also received a contract to haul the mine's coal to the nearest railroad loading point, but when he attempted to open up the mine he was met by armed members of the Local 5881, who threatened Gibbs and beat an SLU organizer. After this one instance of violence a peaceful picket line was maintained for nine months. Gibbs lost his position as superintendent and was never able to begin performance of the haulage contract. Gibbs filed suit against the UMW alleging, among other things, "an unlawful conspiracy and an unlawful boycott aimed at him to maliciously, wantonly and willfully interfere with his contract of employment and with his contract of haulage." (Id. at 720.) The Supreme Court of the United States ruled that "the permissible scope of state remedies in this area is strictly confined to the direct consequences of such violent conduct, and does not include consequences resulting from associated peaceful picketing or other union activity." (Id. at 729.)