United Mine Workers of America v. Gibbs, 383 U.S. 715 (1966)
A federal court has discretion to review a state claim when there is a substantial federal claim in the same action, and the relationship between the federal claim and the state claim suggests that the entire action comprises one case.
Gibbs brought a claim against UMW under Tennessee and federal laws, based on allegations of a conspiracy. UMW members had used force in preventing the opening of a mine, although UMW did not order or approve of these activities, and it was not even aware of them. The company that operated the mine was a subsidiary of a company that had fired 100 miners who were members of UMW, and they saw the opening of the new mine as a breach of their contract with the parent company. Gibbs had a contract for coal haulage with the company that operated the mine, so he argued that UMW had interfered with this contract and with his contract with the subsidiary for worker supervision.
Although the court dismissed the claim based on federal law, it sustained the damages award based on state law.
- William Joseph Brennan, Jr. (Author)
- Earl Warren
- Hugo Lafayette Black
- William Orville Douglas
- Potter Stewart
- Byron Raymond White
- Abe Fortas
When the relationship between a federal claim and a state claim comprises a single case, a federal court may hear both of them under its pendent jurisdiction powers, although it is not required to hear both of them. A decision to exercise pendent jurisdiction should be reviewed under an abuse of discretion standard, which is not met in this case because the state law damages award was not affected by the success of the federal law claims. In this situation, the plaintiff would be expected to try all of these related claims in the same proceeding, and the fact that the claim was heard in federal court does not mean that the award of damages based on state law is invalid.
- John Marshall Harlan II (Author)
- Tom C. Clark
This case concerns pendent jurisdiction, which allows the combination of state claims with federal claims in federal court to support judicial economy. Ancillary jurisdiction is a similar concept applied to adding parties rather than claims.
U.S. Supreme CourtUnited Mine Workers v. Gibbs, 383 U.S. 715 (1966)
United Mine Workers of America v. Gibbs
Argued January 20, 1966
Decided March 28, 1966
383 U.S. 715
A coal company closed a mine in Tennessee and laid off miners belonging to one of petitioner's local unions. Thereafter, the company, through a subsidiary, attempted to open a new mine nearby with members of a rival union. Respondent was hired as mine superintendent and given a contract to truck coal to the nearest rail loading point. On August 15 and 16, 1960, armed members of petitioner's local forcibly prevented the opening of the mine, threatened respondent, and assaulted an organizer for the rival union. Petitioner's area representative was away at a union board meeting when he learned of the violence. He returned late on August 16 with instructions to establish a limited picket line, prevent further violence, and to see that neighboring mines were not struck. There was no further violence at the mine site; a picket line was maintained for nine months, and no further effort was made to open the mine. Respondent lost his job as superintendent, never performed his haulage contract, and allegedly lost other trucking contracts and mine leases because of a concerted union plan against him. Suing only the international union, he sought recovery under § 303 of the Labor Management Relations Act and the common law of Tennessee. Jurisdiction was premised on allegations of secondary boycotts under § 303, and the state law claim, for which jurisdiction was based on the doctrine of pendent jurisdiction, asserted an unlawful conspiracy and boycott to interfere with respondent's contracts of employment and haulage. The jury found that petitioner had violated both § 303 and state law, and respondent was awarded actual and punitive damages. On motion, the trial court set aside the damages award with respect to the haulage contract on the ground that damage was not proved. It also held that union pressure on respondent's employer to discharge him would constitute only a primary dispute with the employer, not cognizable under § 303. Interference with employment was cognizable as a state claim, and a remitted award was sustained thereon. The Court of Appeals affirmed.
1. The District Court properly entertained jurisdiction of the claim based on state law. Pp. 383 U. S. 721-729.
(a) The state law claim, based in part on violence and intimidation, was not preempted by § 303. P. 383 U. S. 721.
(b) Pendent jurisdiction, in the sense of judicial power, exists whenever there is a substantial federal claim and the relationship between it and the asserted state claims permits the conclusion that the entire action before the court comprises one "case." P. 383 U. S. 725.
(c) Pendent jurisdiction is a doctrine of discretion, justified by judicial economy, convenience and fairness to litigants. P. 383 U. S. 726.
(d) The District Court did not exceed its discretion in exercising jurisdiction over the state law claim. Pp. 383 U. S. 727-729.
2. State law remedies against violence and threats of violence arising in labor disputes have been sustained against the challenge of preemption by federal labor legislation, but the scope of such remedies is confined to the direct consequences of such conduct. Pp. 383 U. S. 729-731.
3. Although petitioner concedes that violence which would justify application of such limited state tort law occurred during the first two days of the strike, it appeared that neither the pleadings, arguments of counsel, nor the instructions to the jury adequately defined the area within which damages could be awarded under state law, where the tort claimed, essentially a "conspiracy" to interfere with respondent's contractual relations, was not itself so limited. Pp. 383 U. S. 732-735.
4. Since petitioner was not clearly proved to have participated in or authorized the two days' violence, nor to have ratified it or built its picketing campaign upon the fear of the violence engendered, the special proof requirements of § 6 of the Norris-LaGuardia Act were not satisfied, and petitioner cannot be held liable to respondent under state law. Pp. 383 U. S. 735-742.
(a) While the Labor Management Relations Act expressly provides that, for purposes of that Act, including § 303, the union's responsibility for acts of its members and officers is to be measured by ordinary agency standards, rather than § 6's more stringent standard of "clear proof," it does not displace § 6 for other purposes, and § 6 plainly applies to federal court hearings of state tort claims arising out of labor disputes. Pp. 383 U. S. 736-737.
(b) The "clear proof" language of § 6 is similar to "clear, unequivocal, and convincing proof," used elsewhere. Although, under this standard, the plaintiff in a civil suit does not have to satisfy the criminal standard of reasonable doubt, he is required to persuade by a substantial margin, and to come forward with more than a bare preponderance of the evidence. P. 383 U. S. 737.
(c) Respondent did not present clear proof that petitioner authorized or participated in the violence, or that it ratified the violence which had occurred, and, accordingly, cannot recover from petitioner. Pp. 383 U. S. 738-742.
343 F.2d 609, reversed.