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Lewis v. Benedict Coal Corp.

United States Supreme Court

361 U.S. 459 (1960)

Relevant factsFree

Benedict Coal (defendant) and other companies signed a collective-bargaining agreement with the United Mine Workers, promising to pay agreed wages and contribute a share of profits to a welfare fund benefiting all covered employees, based on each company's coal production. Benedict contributed only about half of what it owed, and welfare-fund trustees, including John Lewis (plaintiff), sued to recover the shortfall; Benedict argued it wasn't obligated because the union had also breached the agreement's no-strike provisions, which Benedict claimed were part of the union's consideration for the deal. The lower courts allowed Benedict to raise the union's breach as a defense, and the Supreme Court granted certiorari.

IssueFree

Whether, absent express language to the contrary, a union's breach of a collective-bargaining agreement affects the employer's contractual duties to employees as third-party beneficiaries of the agreement.

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