United Mine Workers of America v. Gibbs

Brief Fact Summary.

Respondent sued Petitioner under federal and state law for interfering with his mining 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 job. 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 and in response sued Petitioner for violation of § 303 of the Labor Management Relations Act and the common law of Tennessee.

Issue.

Did the District Court for the Eastern District of Tennessee have authority over Respondent’s claim under Tennessee common law?

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 the “common nucleus” requirement of pendent jurisdiction. Under this requirement, the Court found that the District Court had discretion to hear Respondent’s state law claim. The Respondent’s first claim for federal law violations satisfied federal question jurisdiction and Respondent’s second claim for state law violations arose from the same transaction and at least partially implicated federal doctrine.