International Union, United Mine Workers v. Bagwell
United States Supreme Court
512 U.S. 821 (1994)
During a protracted labor dispute, mining companies (plaintiffs) obtained an injunction barring the United Mine Workers (the Union) (defendant) from unlawful strike activity; the trial court later announced that future violations would trigger predetermined fines, and after further hearings found the Union in contempt for over 400 violations, imposing more than $64 million in fines — about $12 million payable to the companies and the rest to state and county governments — all without a jury. The companies and Union later settled and agreed to vacate the fines; the trial court discharged the company-payable portion but refused to vacate the government-payable portion, appointing John Bagwell (plaintiff) to collect it. The Virginia Court of Appeals reversed, but the Supreme Court of Virginia upheld the fines, and the Union sought U.S. Supreme Court review.
Whether contempt proceedings based on out-of-court disobedience of a complex injunction, seeking to impose noncompensatory fines, must utilize criminal procedural protections such as the right to a jury trial.