International Union, United Mine Workers Of America v. Bagwell

512 U.S. 821 (1994)

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Nature of the Case

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Facts

The UMW (D) was in a protracted labor dispute with Clinchfield Coal Company (P1). P1 filed suit against D to enjoin D from conducting unlawful strike-related activities. The injunction was issued, and D was prohibited from obstructing ingress and egress to P1’s facilities, from throwing objects and from threatening P employees, from placing jack rocks on the roads used by P1’s vehicles and from picketing with more than the specified numbers of people. D was also ordered to place supervisors at picket sites and to help its members obey the orders and to report all violations to the court. In the first hearing, the court fined the union $642,000 for its disobedience and announced that it would fine the union $100,000 for any future violent breach of the injunction and $20,000 for any future nonviolent infraction. The court stated its purpose was to impose prospective civil fines, which would only be required if it were shown Ds disobeyed the Court's orders. In six subsequent contempt hearings, the court found D in contempt for more than 400 separate violations of the injunction, many of them violent. The court levied over $64 million in fines against the union of which $12 million was ordered to be paid to P1. The remaining $52 million was ordered paid to the Commonwealth of Virginia and the counties for their continued burden of law enforcement. Each contempt hearing was conducted as a civil proceeding before the trial judge, in which the parties conducted discovery, introduced evidence, and called and cross-examined witnesses. The trial court required that contumacious acts be proved beyond a reasonable doubt, but did not afford D a right to jury trial. While the appeals from the contempt orders were pending, the labor dispute was settled, and they agreed to vacate the contempt fines and jointly moved to dismiss the case. The court vacated the monies to be paid to P1 but refused to vacate the $52 million as they were coercive civil fines and were payable to the public. Bagwell (P) was appointed special commissioner to collect the fines. The Court of Appeals of Virginia reversed and ordered the contempt fines vacated pursuant to the settlement agreement. The Supreme Court of Virginia reversed; Virginia public policy did not permit the private settlement of coercive civil contempt sanctions. The Supreme Court of Virginia held that the court's prospective fine schedule was intended to coerce compliance with the injunction and the union could avoid the fines through obedience, the court reasoned, the fines were civil and coercive and properly imposed in civil proceedings. The court rejected the contention that the fines were criminal and could not be imposed absent a criminal trial. The Supreme Court granted certiorari.