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Publication Date

3-1995

Document Type

Casenote

Abstract

United Mine Workers v. Bagwell involves the imposition of indirect contempt fines stemming from a labor dispute in Virginia. In April 1989, respondents Clinchfield Coal and Sea "B" Mining Companies filed suit to enjoin petitioner International Union, United Mine Workers of America from conducting unlawful strike activities. The trial court entered an injunction that prohibited the union and its members from undertaking illegal strike-related activities. In subsequent hearings, the court imposed over $64,000,000 in fines. The trial court required that the companies prove violations of the injunction beyond a reasonable doubt but did not afford the union the right to a jury trial. While the contempt order was on appeal the parties settled the labor dispute through an agreement that vacated the contempt fines. The trial court granted the parties' joint motion to dismiss, lifted the injunction, and vacated the fines that were payable to the companies. The trial court determined that the remaining $52,000,000 was not absolved through the settlement and was still owed by the unions. Since the companies had withdrawn from the action and local Commonwealth Attorneys disqualified themselves, the trial court appointed John L. Bagwell to collect the remaining fines on behalf of the Commonwealth. The Court of Appeals of Virginia reversed the order imposing contempt fines and ordered that the contempt fines be vacated pursuant to the settlement agreement. The Supreme Court of Virginia reversed and held that since the fines were civil, imposition of the fines did not require a jury trial. The Supreme Court granted certiorari and reversed. Indirect criminal contempts involving fines in excess of fifty million dollars are of such serious nature that the contemnor is entitled to full criminal process including a jury trial.

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