Coronado Coal Co. v. United Mine Workers

Background

A group of coal companies led by the Bache-Denman Coal Company sued union organizations after violent episodes in 1914 destroyed their mining property and killed workers. The companies say union members attacked company guards, sank pumps, and later returned with weapons and dynamite to wreck mines so the companies could not ship coal. The defendants included a large national union, a regional body called District No. 21, several local unions, and some individual leaders. The companies sought damages under the Federal Anti-Trust Act, claiming the violence was aimed at stopping the plaintiffs from competing in interstate coal markets.

Reasoning

The Court examined whether the national union had authorized or financed the local violence and whether the regional and local unions intended to restrain interstate commerce by destroying the mines. The Court found no solid proof that the national executives officially approved or paid for the strike, so it affirmed dismissal of the national union. At the same time, new trial evidence showed leaders of District No. 21 organized, armed, and carried out attacks with the likely aim of stopping non-union coal from reaching other States. The Court concluded that evidence could support a finding that the regional and local unions intended to restrain interstate commerce and therefore reversed the judgment for those defendants and ordered a new trial.

Real world impact

The decision leaves the national union free on the record before the Court but exposes regional and local union leaders to a fresh trial on claims they tried to prevent coal shipments to other States. The outcome at retrial could permit the coal owners to recover damages if jurors find the unions intentionally stopped interstate trade.