United Mine Workers of America v. Gibbs

United Mine Workers of America v. Gibbs
Supreme Court of the United States
Argued January 20, 1966 Decided March 28, 1966
Full case name	United Mine Workers of America v. Gibbs
Citations	383 U.S. 715 (more) 86 S.Ct. 1130, 16 L.Ed.2d 218
Prior history	343 F.2d 609 (6th cir., 1965), reversed.
Holding
In order for a United States district court to have pendent jurisdiction over a state-law cause of action, state and federal claims must arise from the same "common nucleus of operative fact" and the plaintiff must expect to try them all at once.
Court membership
Case opinions
Majority	Brennan, joined by Black, Douglas, Stewart, White, Fortas
Concurrence	Harlan, joined by Clark
Warren took no part in the consideration or decision of the case.
Laws applied
U.S. Const., Art. III § 2; Labor-Management Relations Act

United Mine Workers of America v. Gibbs, 383 U.S. 715 (1966), was a case in which the Supreme Court of the United States held that in order for a United States district court to have pendent jurisdiction over a state-law cause of action, state and federal claims must arise from the same "common nucleus of operative fact" and the plaintiff must expect to try them all at once. This case was decided before the existence of the current supplemental jurisdiction statute, 28 U.S.C. § 1367.

This case arose out of a dispute between two labor unions over the representation of coal miners in Marion County, Tennessee. Plaintiff Paul Gibbs was a truck driver and coal miner who had been hired by the Grundy Company, a wholly owned subsidiary of the Tennessee Consolidated Coal Company, to be the superintendent of a coal mine to be opened near Gray's Creek, and to arrange for the coal to be hauled to the nearest railroad depot. The mine would have been within the jurisdiction of United Mine Workers of America (UMW) Local 5881, whose members had previously worked for Tennessee Consolidated. Gibbs had planned instead to use members of the rival Southern Labor Union to work the mine.

News of the mine's planned opening reached the UMW members, and on August 15 and 16, 1960, a group of armed miners from Local 5881 arrived at the site to prevent the mine from being opened. They threatened Gibbs, and beat the Southern Labor Union representative. UMW field representative George Gilbert was away on business in Middlesboro, Kentucky at the time of the incident, and learned of the violence while he was away. Gilbert returned to the site, and established a picket line, which lasted for nine months. There was no further violence at the site, and no further attempts were made by any party to open the mine.