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The United States Supreme Court in Carbon Fuel Co. v. United Mine Workers held that an international union or its regional subdivision cannot be held liable to an employer for damages resulting from a "wildcat strike"' because it failed to use its best efforts to bring about an end to the unauthorized work stoppage. This holding reflects an effort by the Court to resolve the long standing conflict among the circuits on this issue.

Plaintiff, a coal mine owner and operator, originally brought suit against three local unions of the United Mine Workers of America (UMWA), UMWA District 17 and the international union in federal district court pursuant to section 301 of the Labor Management Relations Act (LMRA). Plaintiff sought damages and injunctive relief for forty-eight unauthorized work stoppages which had occurred at several of his mines over a five-year period. He alleged that the unauthorized work stoppages violated the mandatory arbitration provision contained in the collective bargaining agreement of the parties. Plaintiff further asserted that the international and district unions' failure to use all reasonable means available to prevent the strikes or bring about their termination rendered them liable to him for the ensuing damages.