United Mine Workers v. Gibbs

Brief Fact Summary.

Gibbs brought an action in federal district court against the United Mine Workers’ international union. He alleged violations of federal labor law and state common law, based on local union members’ interference with the operation of a new mine. The trial judge decided, among other things, to entertain the state law claim. The Supreme Court granted certiorari.

Synopsis of Rule of Law.

The doctrine of pendent jurisdiction is one of discretion; if considerations of judicial economy, convenience and fairness to litigants are not present, a federal court should hesitate to exercise jurisdiction over state law claims.

Facts.

Gibbs was hired as a mine superintendent to open a new mine. He was also given contract to haul the new mine’s coal. A conflict arose between local members of the United Mine Workers’ union and a rival union over whose members were to work on the new mine. Local members of the United Mine Workers’ local mine workers’ international union forcibly prevented opening of the mine. Gibbs brought an action in federal district court against the United Mine Workers’ international union, alleging violations of federal labor law and state common law. He was awarded compensatory and punitive damages. The trial judge decided, among other things, to entertain the state law claim. The United States Supreme Court granted certiorari.

Issue.

Did the federal district court properly entertain jurisdiction over the claim based on state (Tennessee) law?

Held.

Yes. The district court did not err in refusing to dismiss the state law claim.

Discussion.

Respondent’s state and federal claims arose form the same nucleus of operative facts and reflected alternative remedies. Although the only recovery ultimately allowed was on the state law claim, the federal issues were not so remote or minor as to warrant finding that only the state law claim was tried.