United Mine Workers v. Gibbs

Brief Fact Summary.

Paul Gibbs (Respondent) sued the international union, United Mine Workers (Petitioner), under state and federal law for interference with his mine leases.

Synopsis of Rule of Law.

Under pendent jurisdiction, a federal claim and state claim constitute one constitutional case if they arise out of a “common nucleus of operative fact.”

Facts.

Tennessee Consolidated Coal Company shut down a mine, causing 100 mine workers affiliated with the international union, United Mine Workers (Petitioner), to lose their jobs. The company’s subsidiary, Grundy Company, then hired Paul Gibbs (Respondent) to open a new mine in the area using miners from a rival union, Southern Labor Union. Local members of Petitioner’s union forcibly prevented the mine from opening. Respondent lost his job as well as other mining leases. Respondent sued Petitioner for interference with his mine leases in the District Court for the Eastern District of Tennessee under both state and federal law.

Issue.

Did the District Court have subject matter jurisdiction over Respondent’s state law claim alongside his federal claim?

Held.

Yes, under pendent jurisdiction the District Court had discretion to hear Respondent’s state law claim. But the case was reversed for other reasons.

Discussion.

The Court relied on precedent requiring a sufficient connection between claims to develop this “common nucleus” test under pendent jurisdiction. Under this test, the Court found that the District Court had discretion to hear Respondent’s state law claim. The Respondent’s claim for federal law violations satisfied federal question jurisdiction and Respondent’s claim for state law violations arose from the same transaction and at least partially implicated federal doctrine.