Muniz v. Hoffman
Annotate this Case
422 U.S. 454 (1975)
U.S. Supreme Court
Muniz v. Hoffman, 422 U.S. 454 (1975)
Muniz v. Hoffman
Argued March 24, 1975
Decided June 25, 1975
422 U.S. 454
After their request for a jury trial was denied, petitioners, a labor union officer and the union, were adjudged guilty of criminal contempt for violating temporary injunctions issued by the District Court pursuant to § 10(l) of the National Labor Relations Act (NLRA) against picketing of an employer pending the National Labor Relations Board's final disposition of the employer's unfair labor practice charge against such picketing. The District Court suspended sentencing of the officer and placed him on probation, but imposed a $10,000 fine on the union. On appeal, the Court of Appeals rejected petitioners' claims that they had a statutory right to a jury trial under 18 U.S.C. § 3692, which provides for jury trial in contempt cases arising under any federal law governing the issuance of injunctions "in any case" growing out of a labor dispute, and that they also had a right to a jury trial under the Constitution (the latter question being limited in this Court to whether the union had such a constitutional right).
1. Petitioners are not entitled to a jury trial under 18 U.S.C. § 3692. Pp. 422 U. S. 458-474.
(a) It is clear from § 10(l) of the NLRA, as added by the Labor Management Relations Act (LMRA), and related sections, particularly § 10(h) (which provides that the courts' jurisdiction to grant temporary injunctive relief or to enforce or set aside an NLRB unfair practice order shall not be limited by the Norris-LaGuardia Act), and from the legislative history of such sections, that Congress not only intended to exempt injunctions authorized by the NLRA and the LMRA from the Norris-LaGuardia Act's limitations, including original § 11 of the latter Act (now repealed) requiring jury trials in contempt actions arising out of that Act, but also intended that civil and criminal contempt proceedings enforcing those injunctions were not to afford contemnors the right to a jury trial. By providing for labor Act injunctions outside the Norris-LaGuardia Act's framework, Congress necessarily contemplated that there would be no right to a jury trial in such contempt proceedings. Pp. 422 U. S. 458-467.
(b) Absent an express provision or any indication in the Reviser's Note to 18 U.S.C. § 3692 that a substantive change in the law was contemplated, no intention on Congress' part to change its original intention that there be no jury trials in contempt proceedings arising out of NLRA injunctions is shown by the fact that § 11 of the Norris-LaGuardia.Act was repealed and replaced by § 3692 as part of the 1948 revision of the Criminal Code. Just as § 3692 may not be read apart from other relevant provisions of the labor law, that section likewise may not be read isolated from its legislative history and the revision process from which it emerged, all of which place definite limitations on this Court's latitude in construing it. Pp. 422 U. S. 467-474.
2. Nor does petitioner union have a right to a jury trial under Art. III, § 2, of the Constitution and the Sixth Amendment. Despite 18 U.S.C. § 1(3), which defines petty offenses as those crimes "the penalty for which does not exceed imprisonment for a period of six months or a fine of not more than $500, or both," a contempt need not be considered a serious crime under all circumstances where the punishment is a fine of more than $500, unaccompanied by imprisonment. Here, where it appears that petitioner union collects dues from some 13,000 persons, the $10,000 fine imposed was not of such magnitude that the union was deprived of whatever right to a jury trial it might have under the Sixth Amendment. Pp. 422 U. S. 475-477.
492 F.2d 929, affirmed.
WHITE, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, BLACKMUN, and REHNQUIST, JJ., joined. DOUGLAS, J., filed a dissenting opinion, post, p. 422 U. S. 478. STEWART, J., filed a dissenting opinion, in which MARSHALL and POWELL, JJ., joined, post, p. 422 U. S. 481.