Summary of United Mine Workers of America v. Gibbs, U.S. Supreme Court (1966)
Cause of action: Gibbs sued in Federal Court against just the UMW, and not either local union or its members. The suit was for a secondary boycott claim under a section of the federal Labor Management Relations Act and a state law cause of action claiming malicious interference with his employment contractual relations and seeking punitive damages that were unavailable under federal law.
Procedural History: Jury found in favor of Gibbs, awarding him compensatory and punitive damages; trial court set aside jury verdict as to the federal claim on the ground the challenged conduct did not constitute a secondary boycott as a matter of law, but sustained the award on the state claim. 6th Circuit affirmed both rulings.
Facts: Gibbs was employed to be a mine superintendent in a new location for a wholly owned subsidiary mine company. Miners, who were represented by a local union of the United Mine Workers, roughed up Gibbs when they learned about his using other laborers from a rival union. Gibbs sued for damages as the result of missing work from his injuries.
Issue(s): Under civil procedure, does a mine worker have the right to attach a state claim for damages, which is the only place he could find monetary relief, along with a federal suit against a national mine company in Federal District Court, when his damages were the result of a physical altercation with local mine workers represented by the same national mine union?
Court’s Rationale/Reasoning: Pendent jurisdiction is a doctrine of discretion, not of PL’s right. The bases are judicial economy, convenience and fairness to litigants. If federal claims are dismissed, the state claims are out as well. The same thing goes if the state portion of the complaint is thrown out. Some cases exist where a state claim can be dismissed w/o prejudice and tried in a state court. Sometimes the issues are so strongly tied together they must be tried in a federal court.
The district court did not exceed its discretion in proceeding to judgment on the state claim. Although section 303 limited recovery to compensatory damages based on secondary pressures, and state law allowed both compensatory and punitive damages, and allowed such damages as to both secondary and primary activity, the state and federal claims arose from the same nucleus of operative fact and reflected alternative remedies.
Rule: Requirements for pendent jurisdiction: whenever there is a claim arising under the Constitution, the laws of the United States, and Treaties made, or which shall be made, under their authority (Article III, section 2), and the relationship between that claim and the state claim permits the conclusion that the entire action before the court comprises but one constitutional “case.”
The federal claim must have substance sufficient to confer subject matter jurisdiction on the court. The state and federal claims must derive from a common nucleus of operative fact. But 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 substantiality of the federal issues, there is power in federal courts to hear the whole.
Holding: Yes, however the district court was well within its discretion when it threw out the federal charge. There may have been confusion in not keeping both charges together and not throwing the state charge out as well, but the Court finds no error in the lower court.