Latrobe Steel Co. v. United Steelworkers of America
United States Court of Appeals for the Third Circuit
545 F.2d 1336 (1976)
Latrobe Steel Company (Latrobe) (plaintiff) had a collective-bargaining agreement with United Steelworkers of America and its Local Union No. 1537 (United) (defendants) containing a no-strike clause; when a separate office-workers' union set up a picket line after failed negotiations with Latrobe, United's production workers refused to cross it. Latrobe sued under section 301 of the Labor Management Relations Act, obtaining a preliminary injunction against the work stoppage and, after continued noncompliance, a civil-contempt order imposing escalating daily fines; United appealed, arguing the district court lacked jurisdiction to issue the injunction in the first place, which should void the contempt order.
Whether a coercive civil-contempt order will survive the invalidation of the underlying injunction.