Yablonski v. United Mine Workers of America

Joseph Yablonski and 48 others (plaintiffs) sued the United Mine Workers of America (UMWA) (defendant) and three of its officers for mishandling union funds under federal labor law. The law firm Williams & Connolly (W&C) initially represented both UMWA and the three officers, then withdrew from representing the officers while continuing to represent UMWA alone. The plaintiffs moved to disqualify W&C entirely, arguing a conflict of interest existed between the union and its officers. The district court denied disqualification and let W&C keep representing UMWA; the plaintiffs appealed.

Whether an attorney may represent a corporation and its individual officers when a present, or possibly future, conflict of interest exists between their respective interests.