International Longshoremen's Ass'n v. Phila. Marine Trade Ass'n

In International Longshoremen's Ass'n v. Phila. Marine Trade Ass'n, 389 U.S. 64, 76, 88 S.Ct. 201, 19 L.Ed.2d 236 (1967), the parties disputed the meaning of a provision in a collective bargaining agreement. 389 U.S. at 65, 88 S.Ct. 201. The union argued that the "set-back" provision entitled the workers to a partial day's pay when the start of their work day was postponed due to unfavorable weather conditions, while the employers argued that the workers were entitled to no more than one hour's pay. Id. at 65-66, 88 S.Ct. 201. An arbitrator ruled that the employer's reading of the set-back provision was correct, but the union refused to work unless the employers adopted the contrary interpretation. Id. at 66-68, 88 S.Ct. 201. At the request of the employers, the district court entered an order requiring the union "to comply with and to abide by the arbitrator's award." Id. at 69, 88 S.Ct. 201. The district court later found the union in contempt of the order because it had engaged in a strike designed to require the employers to provide the increased set-back pay. Id. at 72, 88 S.Ct. 201. The Supreme Court reversed the contempt finding because "the order ... did not state in `specific ... terms' the acts that it required or prohibited." Id. at 76, 88 S.Ct. 201 (quoting Fed.R.Civ.P. 65(d)). In International Longshoremen, the record of the lower court proceedings made it abundantly clear that the alleged contemnor did not understand the terms of the order, repeatedly telling the district court, "I don't know what this order means," but receiving no clarification. 389 U.S. at 70-71, 88 S.Ct. 201. Indeed, the order there was simply a blanket statement requiring the union to "to comply with and to abide by the said arbitrator's Award," but the award contained "only an abstract conclusion of law, not an operative command capable of `enforcement.'" Id. at 74, 88 S.Ct. 201 (holding that the order at issue could "only be described as unintelligible"). The Supreme Court expressly explained that "we do not deal here with a violation of a court order by one who fully understands its meaning but chooses to ignore its mandate." Id. at 76, 88 S.Ct. 201.