United Mine Workers v Gibbs
383 U. S. 715 [1966]
Author:- Sam Biers

Relevant Facts: Res Gibbs was hired to run a mine and to haul coal.  IN 1960 armed members of Local 5881 forcibly prevented the opening of the mine, threatened the Res and beat an organizer for the rival union. There was no UMW rep present.  He was attending a Board meeting in Kentucky and did not return until late the next day.  Whereupon he established a limited picket line, prevented further violence, and insured the strike did not extend to other mines. The picket line lasted for 9 mos with no further violence. Res lost his job as superintendent and did no perform under his K to haul coal. He sought relief against the International Union.

Legal Issue(s): Whether the Federal District Ct properly maintained pendant jurisdiction of the Res claims for conspiracy, and unlawful boycott, and contractual interference based on TN law?

Court’s Holding: Yes

Procedure: D Ct refused to dismiss state claim and entered judgment for Pl on federal claim, both parties appealed; Ct App Affirmed; S. Ct. Reversed.

Law or Rule(s): Pendent jurisdiction exists whenever there is a claim arising under the Const, the laws of the U. S. and treaties and the relationship between that claim and the state claim permits the conclusion that the entire action before the ct comprises on Consti. case.

Court Rationale:   State law claims are appropriate for federal ct determination if they form a separate but parallel ground for relief also sought in a substantial claim based on federal law. A permissible exercise of federal power over a state claim involves a case where two distinct grounds in support of a single cause of action are alleged, and only one of which presents a federal question.  Where the federal question averred to is not plainly wanting in substance, the federal ct, even though the federal ground is not established, may retain and dispose of the case upon a non-federal ground. The state and federal claims must derive from a common nucleus of operative fact. If considered w/o regard to their federal or state character, a Pl’s claims are such that he would ordinarily be expected to try them all in one judicial proceeding, then assuming the substantiality of the federal issues, there is POWER in federal cts to hear the whole.  Once it appears that a state claim constitutes the real body of a case, to which the federal claim is only an appendage, the state claim may fairly be dismissed. If it appears that state issues substantially predominate, whether in terms of proof, of scope of issues raised, or of comprehensiveness of remedy sought, the state claims may be dismissed without prejudice and left for resolution to state tribunals.  It is w/i the discretion of the D. Ct. to have dismissed the state claim, and there is no err in its refusal to do so.

Plaintiff’s Argument: The scope of the state claim implicates the federal doctrine of pre-emption (Labor Management Relations Act and of the common law of Tennessee).

Defendant’s Argument: The issues tried were so remote from federal law that the federal ct was ultimately trying a state claim, the action was a non-federal cause of action based on TN law.