Gateway Coal v. UMW
Annotate this Case
414 U.S. 368 (1974)
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U.S. Supreme Court
Gateway Coal v. UMW, 414 U.S. 368 (1974)
Gateway Coal v. United Mine Workers of America,
Argued October 15, 1973
Decided January 8, 1974
414 U.S. 368
Certain foremen at petitioner company's coal mine were suspended for falsifying records to show no reduction in airflow at the mine when, in fact, the airflow had been substantially reduced because of the collapse of a ventilation structure. When the company reinstated the foremen while criminal charges were pending against them, the miners, who are represented by respondent union, struck to protest the alleged safety hazard created by retention of the foremen. The union refused the company's offer to arbitrate. The company then brought this action under § 301 of the Labor Management Relations Act, contending that the broad arbitration clause of the collective bargaining agreement governed the dispute. The District Court issued a preliminary injunction requiring the union to end the strike and submit to arbitration, and ordered suspension of the two foremen pending the arbitral decision. The Court of Appeals reversed and vacated the injunction, holding that there was a public policy disfavoring compulsory arbitration of safety disputes and that, absent an express provision of the collective bargaining agreement, the union had no contractual duty to submit the controversy to arbitration, and hence no implied obligation not to strike.
1. The arbitration clause of the collective bargaining agreement covering, inter alia, "any local trouble of any kind aris[ing] at the mine," is sufficiently broad to encompass the instant dispute, the foremen's continued presence in the mine being plainly a local issue. Pp. 414 U. S. 374-380.
(a) On its face, such contractual language admits of only one interpretation: that the agreement required the union to submit this dispute to arbitration for resolution by an impartial umpire. P. 414 U. S. 376.
(b) The "presumption of arbitrability" (an order to arbitrate the particular grievance should not be denied unless it may be said with positive assurance that the arbitration clause is not susceptible of an interpretation that covers the asserted dispute, and doubts should be resolved in favor of coverage), Steelworkers v. American
2. The duty to arbitrate imposed by the collective bargaining agreement gave rise to an implied no-strike obligation supporting issuance of an injunction against a work stoppage since, in the absence of an explicit expression negating any implied no-strike obligation, the agreement to arbitrate and the duty not to strike should be construed as having coterminous application. Pp. 414 U. S. 380-384.
3. On the facts, § 502 of the Labor Management Relations Act providing that the quitting of labor by employees in good faith because of abnormally dangerous conditions for work shall not be deemed a strike, did not deprive the District Court of authority to enforce the no-strike obligation, the suspension of the foremen pending a final arbitral decision having eliminated any safety issue. Pp. 414 U. S. 385-387.
4. The circumstances of this case satisfy the traditional equitable considerations controlling the availability of injunctive relief, Boys Markets, Inc. v. Retail Clerks Union, 398 U. S. 235, the District Court finding that the union's continued breach of its no-strike obligation would irreparably harm the petitioner, and eliminating any safety issue by suspending the foremen pending a final arbitral decision. P. 414 U. S. 387.
466 F.2d 1157, reversed.
POWELL, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, STEWART, WHITE, MARSHALL, BLACKMUN, and REHNQUIST, JJ., joined. DOUGLAS, J., filed a dissenting opinion, post, p. 388.