United Mine Workers of America v. Bagwell
Encyclopedia
United Mine Workers of America v. Bagwell, 512 U.S. 821
(1994), was a case in which the United States Supreme Court
laid out the constitutional limitations for the use of contempt
powers by court
s.
from undertaking certain unlawful activities (throwing things, threatening, obstructing, and picketing without supervision); when union members repeatedly violated the injunction, the trial court established a schedule of $100,000 fine for future violent breaches, $20,000 fine for future non-violent breaches; after more violations of the injunction, the trial court ended up assessing $64 million, including $12 million to the plaintiff
in the civil case and $52 million to the county and the commonwealth of Virginia. The parties settled, but the trial court refused to vacate the fines to be paid to the county and commonwealth. The Virginia appellate court reversed the trial court, but the Virginia Supreme Court reversed the appellate court. Appeal was then taken to the U.S. Supreme Court.
Therefore, there could be no compensation to the plaintiff as there was no opportunity for the defendant to purge the contempt. Therefore, these were criminal fines, which required appropriate due process—a trial by jury
—which had not been afforded.
Justice Scalia wrote a concurring opinion, expressing concern about the judge also acting as rulemaker and enforcer. Justice Ginsburg also wrote a concurring opinion, joined by Chief Justice Rehnquist, further elucidating the distinction between civil and criminal fines.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1994), was a case in which the United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
laid out the constitutional limitations for the use of contempt
Contempt of court
Contempt of court is a court order which, in the context of a court trial or hearing, declares a person or organization to have disobeyed or been disrespectful of the court's authority...
powers by court
Court
A court is a form of tribunal, often a governmental institution, with the authority to adjudicate legal disputes between parties and carry out the administration of justice in civil, criminal, and administrative matters in accordance with the rule of law...
s.
Facts
A trial court enjoined striking unions in VirginiaVirginia
The Commonwealth of Virginia , is a U.S. state on the Atlantic Coast of the Southern United States. Virginia is nicknamed the "Old Dominion" and sometimes the "Mother of Presidents" after the eight U.S. presidents born there...
from undertaking certain unlawful activities (throwing things, threatening, obstructing, and picketing without supervision); when union members repeatedly violated the injunction, the trial court established a schedule of $100,000 fine for future violent breaches, $20,000 fine for future non-violent breaches; after more violations of the injunction, the trial court ended up assessing $64 million, including $12 million to the plaintiff
Plaintiff
A plaintiff , also known as a claimant or complainant, is the term used in some jurisdictions for the party who initiates a lawsuit before a court...
in the civil case and $52 million to the county and the commonwealth of Virginia. The parties settled, but the trial court refused to vacate the fines to be paid to the county and commonwealth. The Virginia appellate court reversed the trial court, but the Virginia Supreme Court reversed the appellate court. Appeal was then taken to the U.S. Supreme Court.
Issue
Were these fines civil, or were they criminal (in which case due process and jury would be required)?Opinion of the Court
The Court, in an opinion by Justice Blackmun, held that a contempt sanction is civil if it is remedial and for the benefit of the complainant—if it either coerces the defendant into compliance with the court’s order or compensates the complainant for losses sustained. But where a fine is not compensatory, it is civil only if the contemnor is afforded an opportunity to "purge" (avoid or reduce fine through compliance); otherwise, it is criminal contempt.Therefore, there could be no compensation to the plaintiff as there was no opportunity for the defendant to purge the contempt. Therefore, these were criminal fines, which required appropriate due process—a trial by jury
Trial by Jury
Trial by Jury is a comic opera in one act, with music by Arthur Sullivan and libretto by W. S. Gilbert. It was first produced on 25 March 1875, at London's Royalty Theatre, where it initially ran for 131 performances and was considered a hit, receiving critical praise and outrunning its...
—which had not been afforded.
Justice Scalia wrote a concurring opinion, expressing concern about the judge also acting as rulemaker and enforcer. Justice Ginsburg also wrote a concurring opinion, joined by Chief Justice Rehnquist, further elucidating the distinction between civil and criminal fines.
See also
- List of United States Supreme Court cases, volume 512
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court