U.S. Supreme Court
Carbon Fuel Co. v. Mine Workers, 444 U.S. 212 (1979)
Carbon Fuel Co. v. United Mine Workers of America
Argued November 5, 1979
Decided December 10, 1979
444 U.S. 212
Respondent local labor unions engaged in a number of unauthorized or "wildcat" strikes at petitioner employer's coal mines in violation of collective bargaining agreements between petitioner and respondent international union (UMWA). The efforts of respondent regional subdivision (District 17) of UMWA to persuade the miners not to strike and to return to work were uniformly unsuccessful. Petitioner subsequently brought suit against respondents in Federal District Court pursuant to § 301 of the Labor Management Relations Act, 1947, seeking injunctive relief and damages, and judgments were rendered against all respondents. The Court of Appeals affirmed in part the judgments against the local unions but vacated the judgments against UMWA and District 17, holding that the question was not whether UMWA or District 17 did everything they might have done to prevent the strikes or bring about their termination, but whether they instigated, supported, ratified, or encouraged the strikes, and that there was no evidence of the latter conduct.
Held: Neither UMWA nor District 17 can be held liable in damages under the circumstances of this case. No obligation on their part to use all reasonable means to prevent and end unauthorized strikes can be implied in law either because the collective bargaining agreements contained a provision for arbitration of disputes or because the agreements provided that the parties "agree and affirm that they will maintain the integrity of this contract." Pp. 444 U. S. 216-222.
(a) The legislative history of § 301 is clear that Congress limited a union's responsibility for strikes in breach of contract to cases where the union may be found responsible according to the common law rule of agency, and here petitioner failed to prove agency as required by §§ 301(b) and(e). Pp. 444 U. S. 216-218.
(b) The bargaining history of the collective bargaining agreements clearly shows that, whatever the integrity clause of the agreements may mean, the parties purposely decided not to impose on the union chanroblesvirtualawlibrary
an obligation to take disciplinary or other actions to get unauthorized strikers bask to work. Pp. 444 U. S. 218-222.
582 F.2d 1346, affirmed.
BRENNAN, J., delivered the opinion for a unanimous Court.