United Mine Workers of America v. Gibbs

383 U.S. 715, 86 S. Ct. 1130, 16 L. Ed. 2d 218 · Supreme Court of the United States · 1966

Civil Procedure Assigned in 14 casebooks

Case brief summary

Rule

Federal courts can choose to hear a related state law claim along with a federal claim if both come from the same facts. Unions need very strong proof before being blamed for members' violence.

Facts

Gibbs lost his job and contracts after armed local union members violently blocked a mine from opening. He sued the international union, not the local members, under federal and state law.

Procedural history

A jury awarded Gibbs damages on both claims. The judge reduced the award, the appeals court upheld it, and the Supreme Court agreed to review the case.

Issue

Could the federal court properly hear the state law claim with the federal one, and was there enough proof the international union approved the violence to be held responsible?

Holding

The Supreme Court reversed. The federal court could hear both claims together, but there wasn't enough proof the international union caused or approved the violence.

Reasoning

The claims shared enough facts for one court to hear both. But unions can only be blamed for violence with clear proof of approval, and evidence showed the union tried to stop it.

Opinions

Majority (Brennan): Federal courts may hear related state claims with federal claims when they share common facts, but strong proof is needed to hold an international union liable for local violence, which was lacking here.

Concurrences (Harlan, joined by Clark): Agreed the case should be reversed but read the required proof standard more narrowly, focusing on what kinds of inferences about union responsibility are improper.

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Whom did Gibbs sue in this action?

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What were the facts of this case, and what two kinds of claims did Gibbs bring against the UMW?
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