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Keywords

injunctionappealtrialcompliancesustainedjury trial

settlementdefendantdamagesappealtrialcompliancesustainedjury trial

Related Cases

International Union, United Mine Workers of America v. Bagwell, 512 U.S. 821, 114 S.Ct. 2552, 129 L.Ed.2d 642, 146 L.R.R.M. (BNA) 2641, 62 USLW 4705, 128 Lab.Cas. P 11,120

Facts

The International Union, United Mine Workers of America, engaged in a labor dispute with Clinchfield Coal Company and Sea 'B' Mining Company, resulting in a court injunction against unlawful strike-related activities. Following multiple violations of this injunction, the trial court imposed over $64 million in fines on the union, which were intended to be coercive. After the underlying labor dispute was settled, the trial court refused to vacate the fines, leading to appeals that questioned the nature of the fines as either civil or criminal.

Petitioners, the International Union, United Mine Workers of America, and United Mine Workers of America, District 28 (collectively, the union), engaged in a protracted labor dispute with the Clinchfield Coal Company and Sea “B” Mining Company (collectively, the companies) over alleged unfair labor practices. In April 1989, the companies filed suit in the Circuit Court of Russell County, Virginia, to enjoin the union from conducting unlawful strike-related activities.

Issue

Are the contempt fines levied against the union for violations of a labor injunction civil and coercive, or are they criminal fines that require a jury trial for imposition?

The issue before us accordingly is limited to whether these fines, despite their noncompensatory character, are coercive civil or criminal sanctions.

Rule

A contempt fine is considered civil and remedial if it either coerces compliance with a court order or compensates for losses sustained. Conversely, a fine is criminal if it is punitive and can only be imposed through criminal proceedings, including the right to a jury trial.

A criminal contempt fine is punitive and can be imposed only through criminal proceedings, including the right to jury trial. A contempt fine is considered civil and remedial if it either coerces a defendant into compliance with a court order or compensates the complainant for losses sustained.

Analysis

The court determined that the fines imposed on the union were criminal in nature because they were not compensatory and did not provide the union with an opportunity to purge the fines through compliance. The fines were assessed for widespread violations of a complex injunction, which required detailed factfinding and adjudication. The court emphasized that the union was entitled to the protections of a jury trial due to the serious nature of the fines.

In the instant case, neither any party nor any court of the Commonwealth has suggested that the challenged fines are compensatory. At no point did the trial court attempt to calibrate the fines to damages caused by the union's contumacious activities or indicate that the fines were 'to compensate the complainant for losses sustained.'

Conclusion

The Supreme Court reversed the judgment of the Supreme Court of Virginia, holding that the serious contempt fines were criminal and could only be imposed through a jury trial.

Held: The serious contempt fines imposed here were criminal and constitutionally could be imposed only through a jury trial.

Who won?

The International Union, United Mine Workers of America prevailed in the Supreme Court, as the court ruled that the fines imposed were criminal and required a jury trial.

The Court of Appeals of Virginia reversed and ordered that the contempt fines be vacated pursuant to the settlement agreement.

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